Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Supplemental Educational 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 Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (“FSEOG”) (ALN: 84.007)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20).
Condition: The University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds.
Cause: Administrative oversight.
Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements.
Questioned Costs: None.
Context: The University improperly prioritized disbursing FSEOG funds to 2 students during the year over Federal Pell Grant recipients.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that Title IV aid is properly awarded.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The University transitioned from a manual awarding process to an automated process after last year’s audit but not in time to change some of the 23-24 awards. In the past FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. This practice in no longer being followed beginning with the 24-25 academic year. In addition, the Financial Aid office will review all 2024-2025 FSEOG awards to ensure that FSEOG is only awarded to Pell recipients.
Federal Program Information: Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - 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 (“ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from 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 is allowed and considered tolerable 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: Certain instances were identified during the year in which funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements.
Questioned Costs: None.
Context: During our testing, we identified an instance of cash held in excess of allowable time frames for the Federal Work-Study Program. Additionally, we identified an instance of cash held in excess of allowable time frames for the Federal Pell Grant Program. In both instances, excess cash was less than 1% of prior year draws.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: We recommend the University enhance its procedures and internal con trols over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations.
Views of Responsible Officials and Planned Corrective Actions:The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require that the employees that perform the draw requests and the reconciliations review the FWS master worksheet for any pending adjustments.
The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate award reversals that necessitate a refund. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Work-Study (“FWS”) Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Federal Work Study – Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid (34 CFR 675.16(a)(3)). The institution must also establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day (34 CFR 675.19(b)(2)(i)).
Condition: A certain student’s timesheet was not appropriately certified.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with recordkeeping requirements in order to ensure federal awards are disbursed in accordance with federal regulations.
Questioned Costs: None.
Context: For 1 of 40 FWS payments tested, the University was unable to provide documentation evidencing approval by the student’s supervisor.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that all FWS students’ timesheets are appropriately reviewed and approved.
Views of Responsible Officials and Planned Corrective Actions: The instance of non-compliance occurred during a period of software change for timecard recordkeeping. The former software allowed the supervisor to electronically approve a student timecard after payroll was processed. The new software does not allow this and the process now requires manual follow-up and signature. The Payroll Office in combination with Human Resources will enhance training for supervisors and require additional training for those supervisors that fail to approve timecards timely. Reporting has been improved to identify timecards that have not been approved. A procedure change has been implemented to remove wages from FWS if the hours in question remain unapproved after 30 days.
Federal Program Information: Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - 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 (“ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from 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 is allowed and considered tolerable 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: Certain instances were identified during the year in which funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements.
Questioned Costs: None.
Context: During our testing, we identified an instance of cash held in excess of allowable time frames for the Federal Work-Study Program. Additionally, we identified an instance of cash held in excess of allowable time frames for the Federal Pell Grant Program. In both instances, excess cash was less than 1% of prior year draws.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: We recommend the University enhance its procedures and internal con trols over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations.
Views of Responsible Officials and Planned Corrective Actions:The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require that the employees that perform the draw requests and the reconciliations review the FWS master worksheet for any pending adjustments.
The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate award reversals that necessitate a refund. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - 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,” both of which need to be reported accurately and have separate record types. 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.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included an instance in which the error record was not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance 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: We noted the following exceptions as a result of our procedures:
• For 2 of 40 campus level records tested, one or more high risk data elements were not accurately reported.
• For 18 of 40 program level records tested, one or more high risk data elements were not accurately reported.
• For 1 of 8 errors records identified during the fiscal year, the error was not corrected within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-009.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions within the Registrar's Office. To enhance our efforts on this front, the University Registrar will implement additional training measures and reporting SOPs to ensure all status changes and error records are submitted to the NSC/NSLDS website within the required timeframe. These efforts will strengthen accuracy and overall compliance with reporting requirements. Enrollment reporting remains a critical focus of this initiative.
Federal Program Information: Federal Supplemental Educational 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 Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Direct Student Loan Program (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 Notification - 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 ED; 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: Certain borrowers did not receive a loan disbursement notification, or the University was unable to provide a copy of the loan disbursement notification sent to the student.
Cause: Administrative oversight and insufficient internal control.
Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards.
Questioned Costs: None.
Context: For 8 of 40 students selected for testing, the University was unable to provide documentation supporting an appropriate loan disbursement notification.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-007.
Recommendation: We recommend the University enhance its procedures and internal controls over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The Vice President of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans, but some of them were already disbursed before this new process. To further enhance this process the FA Analyst created a process in Colleague to automate this process as well as allow for us to keep better records of the notifications. This new process was implemented in 2024, and the University should see results on the 2024-2025 Audit.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - 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,” both of which need to be reported accurately and have separate record types. 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.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included an instance in which the error record was not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance 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: We noted the following exceptions as a result of our procedures:
• For 2 of 40 campus level records tested, one or more high risk data elements were not accurately reported.
• For 18 of 40 program level records tested, one or more high risk data elements were not accurately reported.
• For 1 of 8 errors records identified during the fiscal year, the error was not corrected within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-009.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions within the Registrar's Office. To enhance our efforts on this front, the University Registrar will implement additional training measures and reporting SOPs to ensure all status changes and error records are submitted to the NSC/NSLDS website within the required timeframe. These efforts will strengthen accuracy and overall compliance with reporting requirements. Enrollment reporting remains a critical focus of this initiative.
Federal Program Information: Federal Supplemental Educational 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 Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Supplemental Educational 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 Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (“FSEOG”) (ALN: 84.007)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Federal Supplemental Educational Opportunity Grant (Assistance Listing 84.007) - The FSEOG program provides grants to eligible undergraduate students who have not previously earned a bachelor’s or first professional degree. Priority is given to Pell Grant recipients who have the lowest expected family contributions. The institution decides the amount of the grant, which can be up to $4,000 but not less than $100, for an academic year (34 CFR 676.10 and 676.20).
Condition: The University did not give priority to Federal Pell Grant recipients when awarding and disbursing FSEOG funds.
Cause: Administrative oversight.
Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements.
Questioned Costs: None.
Context: The University improperly prioritized disbursing FSEOG funds to 2 students during the year over Federal Pell Grant recipients.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-002.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that Title IV aid is properly awarded.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The University transitioned from a manual awarding process to an automated process after last year’s audit but not in time to change some of the 23-24 awards. In the past FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. This practice in no longer being followed beginning with the 24-25 academic year. In addition, the Financial Aid office will review all 2024-2025 FSEOG awards to ensure that FSEOG is only awarded to Pell recipients.
Federal Program Information: Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - 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 (“ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from 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 is allowed and considered tolerable 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: Certain instances were identified during the year in which funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements.
Questioned Costs: None.
Context: During our testing, we identified an instance of cash held in excess of allowable time frames for the Federal Work-Study Program. Additionally, we identified an instance of cash held in excess of allowable time frames for the Federal Pell Grant Program. In both instances, excess cash was less than 1% of prior year draws.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: We recommend the University enhance its procedures and internal con trols over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations.
Views of Responsible Officials and Planned Corrective Actions:The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require that the employees that perform the draw requests and the reconciliations review the FWS master worksheet for any pending adjustments.
The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate award reversals that necessitate a refund. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Work-Study (“FWS”) Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Federal Work Study – Before an institution makes an initial disbursement of FWS compensation to a student for an award period, the institution must notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid (34 CFR 675.16(a)(3)). The institution must also establish and maintain program and fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day (34 CFR 675.19(b)(2)(i)).
Condition: A certain student’s timesheet was not appropriately certified.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with recordkeeping requirements in order to ensure federal awards are disbursed in accordance with federal regulations.
Questioned Costs: None.
Context: For 1 of 40 FWS payments tested, the University was unable to provide documentation evidencing approval by the student’s supervisor.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that all FWS students’ timesheets are appropriately reviewed and approved.
Views of Responsible Officials and Planned Corrective Actions: The instance of non-compliance occurred during a period of software change for timecard recordkeeping. The former software allowed the supervisor to electronically approve a student timecard after payroll was processed. The new software does not allow this and the process now requires manual follow-up and signature. The Payroll Office in combination with Human Resources will enhance training for supervisors and require additional training for those supervisors that fail to approve timecards timely. Reporting has been improved to identify timecards that have not been approved. A procedure change has been implemented to remove wages from FWS if the hours in question remain unapproved after 30 days.
Federal Program Information: Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - 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 (“ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from 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 is allowed and considered tolerable 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: Certain instances were identified during the year in which funds drawn were held in excess of the allowable time frame.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements.
Questioned Costs: None.
Context: During our testing, we identified an instance of cash held in excess of allowable time frames for the Federal Work-Study Program. Additionally, we identified an instance of cash held in excess of allowable time frames for the Federal Pell Grant Program. In both instances, excess cash was less than 1% of prior year draws.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-001.
Recommendation: We recommend the University enhance its procedures and internal con trols over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations.
Views of Responsible Officials and Planned Corrective Actions:The FWS Program instances were the result of retroactive award adjustments that posted subsequent to the federal draws and federal draw reconciliations. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require that the employees that perform the draw requests and the reconciliations review the FWS master worksheet for any pending adjustments.
The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate award reversals that necessitate a refund. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - 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,” both of which need to be reported accurately and have separate record types. 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.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included an instance in which the error record was not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance 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: We noted the following exceptions as a result of our procedures:
• For 2 of 40 campus level records tested, one or more high risk data elements were not accurately reported.
• For 18 of 40 program level records tested, one or more high risk data elements were not accurately reported.
• For 1 of 8 errors records identified during the fiscal year, the error was not corrected within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-009.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions within the Registrar's Office. To enhance our efforts on this front, the University Registrar will implement additional training measures and reporting SOPs to ensure all status changes and error records are submitted to the NSC/NSLDS website within the required timeframe. These efforts will strengthen accuracy and overall compliance with reporting requirements. Enrollment reporting remains a critical focus of this initiative.
Federal Program Information: Federal Supplemental Educational 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 Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56).
Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: For 3 of 16 students selected for verification testing, the University did not perform appropriate verification procedures.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-005.
Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. They also contracted with a third-party servicer that assisted with the verification process. The newly hired staff did not receive the proper training to perform their roles effectively. These two changes led to errors in verifying certain data when performing verification. The Financial Aid office implemented a Quality Assurance two-step verification process, but this took place after some of the 23-24 awards were processed. The Financial Aid office will run a report to identify all students selected for verification for 2024-2025 and review them for accuracy. If any corrections are needed, they will be updated, and awards will be adjusted as needed.
Federal Program Information: Federal Direct Student Loan Program (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 Notification - 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 ED; 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: Certain borrowers did not receive a loan disbursement notification, or the University was unable to provide a copy of the loan disbursement notification sent to the student.
Cause: Administrative oversight and insufficient internal control.
Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards.
Questioned Costs: None.
Context: For 8 of 40 students selected for testing, the University was unable to provide documentation supporting an appropriate loan disbursement notification.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-007.
Recommendation: We recommend the University enhance its procedures and internal controls over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: The Vice President of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans, but some of them were already disbursed before this new process. To further enhance this process the FA Analyst created a process in Colleague to automate this process as well as allow for us to keep better records of the notifications. This new process was implemented in 2024, and the University should see results on the 2024-2025 Audit.
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - 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,” both of which need to be reported accurately and have separate record types. 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.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: The University did not accurately report certain significant data elements to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included an instance in which the error record was not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance 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: We noted the following exceptions as a result of our procedures:
• For 2 of 40 campus level records tested, one or more high risk data elements were not accurately reported.
• For 18 of 40 program level records tested, one or more high risk data elements were not accurately reported.
• For 1 of 8 errors records identified during the fiscal year, the error was not corrected within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-009.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University Registrar has worked to develop and implement a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions within the Registrar's Office. To enhance our efforts on this front, the University Registrar will implement additional training measures and reporting SOPs to ensure all status changes and error records are submitted to the NSC/NSLDS website within the required timeframe. These efforts will strengthen accuracy and overall compliance with reporting requirements. Enrollment reporting remains a critical focus of this initiative.
Federal Program Information: Federal Supplemental Educational 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 Tests and Provisions – 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. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination.
The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)).
Condition: The University did not properly calculate the amounts to be returned and did not timely return funds to ED for certain students tested.
Cause: Administrative oversight and insufficient internal control.
Effect: The University was not in compliance with the return of Title IV funds requirements.
Questioned Costs: Sampled questioned costs: $2,003; total questioned costs: indeterminable.
Context: For 1 of 17 students tested, the University did not properly calculate the amount of Title IV aid to be returned.
For 1 of 17 students tested, the University did not return funds to ED within the required timeframe.
Identification of Repeat Finding: This is a repeat of prior year finding 2023-008.
Recommendation: We recommend the University enhance its procedures and internal controls over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: During the 2024 fiscal year, the Financial Aid office experienced several staffing changes, including hiring a new Director of Financial Aid. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, developed an automated weekly report confirming student withdrawal dates for the 24-25 academic year. The report is emailed to Financial Aid director every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of Title IV funds calculation is performed for those students. Any funds required to be disbursed or returned are then processed.