Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Condition: Certain students’ enrollment information was not accurately or timely reported to the
NSLDS.
Questioned Costs: N/A
Context: During our testing of enrollment information at both the program and campus-level detail, we
noted the following:
• One out of forty students was reported to the NSLDS with an incorrect date of withdrawal on the
campus-level records.
• Two out of forty students were reported to the NSLDS with the incorrect effective date on the
campus -level records.
• One out of forty students had a program length incorrectly reported on the program-level
records of the NSLDS.
Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace
period.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and review regulations to
ensure the University understands the definitions for enrollment information required to be reported to
the NSLDS.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Condition: Certain students’ enrollment information was not accurately or timely reported to the
NSLDS.
Questioned Costs: N/A
Context: During our testing of enrollment information at both the program and campus-level detail, we
noted the following:
• One out of forty students was reported to the NSLDS with an incorrect date of withdrawal on the
campus-level records.
• Two out of forty students were reported to the NSLDS with the incorrect effective date on the
campus -level records.
• One out of forty students had a program length incorrectly reported on the program-level
records of the NSLDS.
Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace
period.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and review regulations to
ensure the University understands the definitions for enrollment information required to be reported to
the NSLDS.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number: P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with CFR 685.200(2)(i), a Direct Subsidized Loan
borrower must demonstrate financial need in accordance with title IV, part F of the Act.
Condition: A student received a Direct Subsidized Loan that did not demonstrate financial need.
Questioned Costs: $5,500
Context: This condition occurred for one out of forty students.
Cause: The University’s controls over the awarding of the appropriate aid based off need were not
functioning as designed.
Effect: A student received Title IV funding for which they were not eligible.
Repeat Finding: No
Recommendation: We recommend the University establish additional policies to ensure all students
meet the financial need criteria before awarding Title IV funds.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires
financial institutions to explain their information-sharing practices to their customers and to safeguard
sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that
participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the
Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and
maintain a comprehensive information security program that is written in one or more readily accessible
parts. The regulations require the written information security program to include nine elements for
institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must
address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the University’s information security program were not maintained in
written form.
Questioned Costs: N/A
Context: As of June 2024, the University’s written information security program did not address the
following requirements:
• Encrypting customer information on the institution’s system and during transit.
• Anticipating and evaluating changes to the information system or network.
• Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)).
• Evaluating and adjusting the information security program based on testing and monitoring
results, material changes to operations or business arrangements, risk assessment results, or
any other circumstances that may materially impact the program (16 CFR 314.4(g)).
Cause: The University’s written policy did not explicitly address the required elements, and there was
no process in place to ensure the written information security program aligned with the requirements.
Effect: Information security management may not be optimized and responses delayed without the
written plan.
Repeat Finding: No
Recommendation: We recommend the University ensure its written information security program
addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding and the University is in
the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires
financial institutions to explain their information-sharing practices to their customers and to safeguard
sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that
participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the
Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and
maintain a comprehensive information security program that is written in one or more readily accessible
parts. The regulations require the written information security program to include nine elements for
institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must
address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the University’s information security program were not maintained in
written form.
Questioned Costs: N/A
Context: As of June 2024, the University’s written information security program did not address the
following requirements:
• Encrypting customer information on the institution’s system and during transit.
• Anticipating and evaluating changes to the information system or network.
• Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)).
• Evaluating and adjusting the information security program based on testing and monitoring
results, material changes to operations or business arrangements, risk assessment results, or
any other circumstances that may materially impact the program (16 CFR 314.4(g)).
Cause: The University’s written policy did not explicitly address the required elements, and there was
no process in place to ensure the written information security program aligned with the requirements.
Effect: Information security management may not be optimized and responses delayed without the
written plan.
Repeat Finding: No
Recommendation: We recommend the University ensure its written information security program
addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding and the University is in
the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires
financial institutions to explain their information-sharing practices to their customers and to safeguard
sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that
participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the
Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and
maintain a comprehensive information security program that is written in one or more readily accessible
parts. The regulations require the written information security program to include nine elements for
institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must
address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the University’s information security program were not maintained in
written form.
Questioned Costs: N/A
Context: As of June 2024, the University’s written information security program did not address the
following requirements:
• Encrypting customer information on the institution’s system and during transit.
• Anticipating and evaluating changes to the information system or network.
• Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)).
• Evaluating and adjusting the information security program based on testing and monitoring
results, material changes to operations or business arrangements, risk assessment results, or
any other circumstances that may materially impact the program (16 CFR 314.4(g)).
Cause: The University’s written policy did not explicitly address the required elements, and there was
no process in place to ensure the written information security program aligned with the requirements.
Effect: Information security management may not be optimized and responses delayed without the
written plan.
Repeat Finding: No
Recommendation: We recommend the University ensure its written information security program
addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding and the University is in
the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program
Assistance Listing Number: 84.063
Federal Award Identification Number: P063P231946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell
grant for an academic year is based upon the payment and disbursement schedules published by the
Secretary for each award year. The payment schedules take into account the cost of attendance, the
student’s Estimated Family Contribution (EFC) and the enrollment status of the student.
Condition: During our testing, it was noted one student was under-awarded Pell due to the University
using incorrect information.
Questioned Costs: N/A
Context: One out of a sample of forty students tested was under-awarded Pell grant funds.
Cause: The University’s process did not ensure the most accurate information was used when
awarding aid.
Effect: The student was under-awarded Pell grant funds.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend the University implement a review process to ensure calculations
of Pell awards are using the correct information.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number: P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.304 requires
entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized
Loan, Direct Unsubsidized Loan, and Direct PLUS Loans to a graduate or professional student. The
regulations also require exit counseling for all students who cease at least half-time study at the school.
Condition: During our testing, it was noted that individuals did not receive exit counseling.
Questioned Costs: N/A
Context: All thirteen students in our sample who either ceased at least half-time study or left the
University, did not receive exit counseling.
Cause: The University did not follow procedures to ensure students who left the University received
exit counseling.
Effect: Students may not fully understand their repayment obligations, leading to higher default rates
on student loans. This can negatively impact the University’s cohort default rate, potentially resulting in
sanctions or loss of eligibility for federal financial aid programs.
Repeat Finding: No
Recommendation: We recommend the University review its process around sending exit counseling
information to students to ensure this information is received and the University is performing required
procedures.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires the University to report the
disbursement dates and amounts to the COD system within 15 days of disbursing Pell and Direct Loan
funds to a student. (34 CFR 690.83(b)(2) and CFR 685.309)
Condition: Disbursements were not reported to COD within the required 15-day timeframe.
Questioned Costs: N/A
Context: During our testing of forty disbursements, we noted one disbursement was not reported to
COD in a timely manner.
Cause: The University’s controls around reporting to COD were not functioning as designed to ensure
timely reporting.
Effect: The University is not in compliance with the Department of Education guidelines.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around
reporting to the COD to ensure that student information is reported timely.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires the University to report the
disbursement dates and amounts to the COD system within 15 days of disbursing Pell and Direct Loan
funds to a student. (34 CFR 690.83(b)(2) and CFR 685.309)
Condition: Disbursements were not reported to COD within the required 15-day timeframe.
Questioned Costs: N/A
Context: During our testing of forty disbursements, we noted one disbursement was not reported to
COD in a timely manner.
Cause: The University’s controls around reporting to COD were not functioning as designed to ensure
timely reporting.
Effect: The University is not in compliance with the Department of Education guidelines.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around
reporting to the COD to ensure that student information is reported timely.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Federal Award Identification Number: P268K241946
Award Period: 7/1/2023 – 6/30/2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires
an institution to reconcile their records with the Direct Loan funds received from the Secretary and the
Direct Loan disbursement records submitted to and accepted by the Secretary monthly.
Condition: Direct loan reconciliations between the COD, G5, and student accounts were not being
performed monthly.
Questioned Costs: N/A
Context: While testing direct loan reconciliations, it was noted that the University did not perform
monthly reconciliations for the three months selected for testing.
Cause: The University’s process to reconcile direct loans on a monthly basis was not followed during
the year.
Effect: The University is not complying with internal policy and federal requirements to ensure funds
are properly reconciled.
Repeat Finding: N/A
Recommendation: The University should ensure all necessary employees receive proper training,
support, and time to follow the University’s policies and federal requirements related to monthly
reconciliations. There should be a process to maintain all reconciliations as support of performance
monthly.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), when a recipient of
Title IV grant or loan assistance withdraws from an institution during a payment period or period of
enrollment in which the recipient began attendance, the institution must determine the amount of Title
IV grant or loan assistance that the student earned as of the student’s withdrawal date.
Condition: During our testing, it was noted that an R2T4 calculation was not completed.
Questioned Costs: N/A
Context: One out of ten students selected for testing should have had a R2T4 calculation completed
upon withdrawing from the University.
Cause: The University’s controls over performing R2T4 calculations were not functioning as designed.
Effect: The University is not following guidelines to calculate and return funds depending upon the date
of the student’s withdrawal.
Repeat Finding: No
Recommendation: We recommend the University review the R2T4 requirements and ensure their
process incorporates a review of students to ensure no calculations are missed that should be
performed.
2024 – 005: Return of Title IV (R2T4) Funds (Continued)
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Condition: Certain students’ enrollment information was not accurately or timely reported to the
NSLDS.
Questioned Costs: N/A
Context: During our testing of enrollment information at both the program and campus-level detail, we
noted the following:
• One out of forty students was reported to the NSLDS with an incorrect date of withdrawal on the
campus-level records.
• Two out of forty students were reported to the NSLDS with the incorrect effective date on the
campus -level records.
• One out of forty students had a program length incorrectly reported on the program-level
records of the NSLDS.
Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace
period.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and review regulations to
ensure the University understands the definitions for enrollment information required to be reported to
the NSLDS.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Condition: Certain students’ enrollment information was not accurately or timely reported to the
NSLDS.
Questioned Costs: N/A
Context: During our testing of enrollment information at both the program and campus-level detail, we
noted the following:
• One out of forty students was reported to the NSLDS with an incorrect date of withdrawal on the
campus-level records.
• Two out of forty students were reported to the NSLDS with the incorrect effective date on the
campus -level records.
• One out of forty students had a program length incorrectly reported on the program-level
records of the NSLDS.
Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace
period.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and review regulations to
ensure the University understands the definitions for enrollment information required to be reported to
the NSLDS.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number: P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: In accordance with CFR 685.200(2)(i), a Direct Subsidized Loan
borrower must demonstrate financial need in accordance with title IV, part F of the Act.
Condition: A student received a Direct Subsidized Loan that did not demonstrate financial need.
Questioned Costs: $5,500
Context: This condition occurred for one out of forty students.
Cause: The University’s controls over the awarding of the appropriate aid based off need were not
functioning as designed.
Effect: A student received Title IV funding for which they were not eligible.
Repeat Finding: No
Recommendation: We recommend the University establish additional policies to ensure all students
meet the financial need criteria before awarding Title IV funds.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires
financial institutions to explain their information-sharing practices to their customers and to safeguard
sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that
participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the
Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and
maintain a comprehensive information security program that is written in one or more readily accessible
parts. The regulations require the written information security program to include nine elements for
institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must
address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the University’s information security program were not maintained in
written form.
Questioned Costs: N/A
Context: As of June 2024, the University’s written information security program did not address the
following requirements:
• Encrypting customer information on the institution’s system and during transit.
• Anticipating and evaluating changes to the information system or network.
• Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)).
• Evaluating and adjusting the information security program based on testing and monitoring
results, material changes to operations or business arrangements, risk assessment results, or
any other circumstances that may materially impact the program (16 CFR 314.4(g)).
Cause: The University’s written policy did not explicitly address the required elements, and there was
no process in place to ensure the written information security program aligned with the requirements.
Effect: Information security management may not be optimized and responses delayed without the
written plan.
Repeat Finding: No
Recommendation: We recommend the University ensure its written information security program
addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding and the University is in
the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires
financial institutions to explain their information-sharing practices to their customers and to safeguard
sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that
participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the
Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and
maintain a comprehensive information security program that is written in one or more readily accessible
parts. The regulations require the written information security program to include nine elements for
institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must
address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the University’s information security program were not maintained in
written form.
Questioned Costs: N/A
Context: As of June 2024, the University’s written information security program did not address the
following requirements:
• Encrypting customer information on the institution’s system and during transit.
• Anticipating and evaluating changes to the information system or network.
• Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)).
• Evaluating and adjusting the information security program based on testing and monitoring
results, material changes to operations or business arrangements, risk assessment results, or
any other circumstances that may materially impact the program (16 CFR 314.4(g)).
Cause: The University’s written policy did not explicitly address the required elements, and there was
no process in place to ensure the written information security program aligned with the requirements.
Effect: Information security management may not be optimized and responses delayed without the
written plan.
Repeat Finding: No
Recommendation: We recommend the University ensure its written information security program
addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding and the University is in
the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires
financial institutions to explain their information-sharing practices to their customers and to safeguard
sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that
participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the
Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and
maintain a comprehensive information security program that is written in one or more readily accessible
parts. The regulations require the written information security program to include nine elements for
institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must
address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the University’s information security program were not maintained in
written form.
Questioned Costs: N/A
Context: As of June 2024, the University’s written information security program did not address the
following requirements:
• Encrypting customer information on the institution’s system and during transit.
• Anticipating and evaluating changes to the information system or network.
• Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)).
• Evaluating and adjusting the information security program based on testing and monitoring
results, material changes to operations or business arrangements, risk assessment results, or
any other circumstances that may materially impact the program (16 CFR 314.4(g)).
Cause: The University’s written policy did not explicitly address the required elements, and there was
no process in place to ensure the written information security program aligned with the requirements.
Effect: Information security management may not be optimized and responses delayed without the
written plan.
Repeat Finding: No
Recommendation: We recommend the University ensure its written information security program
addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding and the University is in
the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Federal Pell Grant Program
Assistance Listing Number: 84.063
Federal Award Identification Number: P063P231946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell
grant for an academic year is based upon the payment and disbursement schedules published by the
Secretary for each award year. The payment schedules take into account the cost of attendance, the
student’s Estimated Family Contribution (EFC) and the enrollment status of the student.
Condition: During our testing, it was noted one student was under-awarded Pell due to the University
using incorrect information.
Questioned Costs: N/A
Context: One out of a sample of forty students tested was under-awarded Pell grant funds.
Cause: The University’s process did not ensure the most accurate information was used when
awarding aid.
Effect: The student was under-awarded Pell grant funds.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend the University implement a review process to ensure calculations
of Pell awards are using the correct information.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number: P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.304 requires
entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized
Loan, Direct Unsubsidized Loan, and Direct PLUS Loans to a graduate or professional student. The
regulations also require exit counseling for all students who cease at least half-time study at the school.
Condition: During our testing, it was noted that individuals did not receive exit counseling.
Questioned Costs: N/A
Context: All thirteen students in our sample who either ceased at least half-time study or left the
University, did not receive exit counseling.
Cause: The University did not follow procedures to ensure students who left the University received
exit counseling.
Effect: Students may not fully understand their repayment obligations, leading to higher default rates
on student loans. This can negatively impact the University’s cohort default rate, potentially resulting in
sanctions or loss of eligibility for federal financial aid programs.
Repeat Finding: No
Recommendation: We recommend the University review its process around sending exit counseling
information to students to ensure this information is received and the University is performing required
procedures.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires
institutions to obtain supporting documentation and perform verification procedures for students
selected by the Central Processing System (CPS). Supporting documents must be retained to support
the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be
obtained for the verification procedures.
Condition: During our testing, students did not have the required support for household verification in
their files.
Questioned Costs: N/A
Context: The condition occurred for one of nine students tested.
Cause: The University’s internal controls regarding verification procedures were not functioning as
designed.
Effect: Failing to verify household size could lead to an incorrect household size which impacts the
calculation of a student’s Expected Family Contribution which is used for calculating federal aid.
Repeat Finding: No
Recommendation: The University should review the procedures surrounding the verification process
to ensure all necessary support and documentation is obtained as well as maintained in student files.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires the University to report the
disbursement dates and amounts to the COD system within 15 days of disbursing Pell and Direct Loan
funds to a student. (34 CFR 690.83(b)(2) and CFR 685.309)
Condition: Disbursements were not reported to COD within the required 15-day timeframe.
Questioned Costs: N/A
Context: During our testing of forty disbursements, we noted one disbursement was not reported to
COD in a timely manner.
Cause: The University’s controls around reporting to COD were not functioning as designed to ensure
timely reporting.
Effect: The University is not in compliance with the Department of Education guidelines.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around
reporting to the COD to ensure that student information is reported timely.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number: P063P231946, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Department of Education requires the University to report the
disbursement dates and amounts to the COD system within 15 days of disbursing Pell and Direct Loan
funds to a student. (34 CFR 690.83(b)(2) and CFR 685.309)
Condition: Disbursements were not reported to COD within the required 15-day timeframe.
Questioned Costs: N/A
Context: During our testing of forty disbursements, we noted one disbursement was not reported to
COD in a timely manner.
Cause: The University’s controls around reporting to COD were not functioning as designed to ensure
timely reporting.
Effect: The University is not in compliance with the Department of Education guidelines.
Repeat Finding: No
Recommendation: We recommend the University evaluate its procedures and policies around
reporting to the COD to ensure that student information is reported timely.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Federal Award Identification Number: P268K241946
Award Period: 7/1/2023 – 6/30/2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires
an institution to reconcile their records with the Direct Loan funds received from the Secretary and the
Direct Loan disbursement records submitted to and accepted by the Secretary monthly.
Condition: Direct loan reconciliations between the COD, G5, and student accounts were not being
performed monthly.
Questioned Costs: N/A
Context: While testing direct loan reconciliations, it was noted that the University did not perform
monthly reconciliations for the three months selected for testing.
Cause: The University’s process to reconcile direct loans on a monthly basis was not followed during
the year.
Effect: The University is not complying with internal policy and federal requirements to ensure funds
are properly reconciled.
Repeat Finding: N/A
Recommendation: The University should ensure all necessary employees receive proper training,
support, and time to follow the University’s policies and federal requirements related to monthly
reconciliations. There should be a process to maintain all reconciliations as support of performance
monthly.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish
and maintain effective internal control over the federal award that provides reasonable assurance that
the nonfederal entity is managing the federal award in compliance with federal statutes, regulations,
and the terms and conditions of the federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework,” issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: During the audit, it was observed that the University did not have adequate segregation of
duties in its financial aid office and did not maintain supporting documentation. The Director of Financial
Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV
funds.
Questioned Costs: N/A
Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed.
There are instances where the Director of Financial Aid is reviewing and approving financial aid
packages, reconciliations and other required reports. We also noted instances were supporting
documentation could not be provided.
Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in
inadequate segregation of duties.
Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and
inaccuracies in awarding and reporting of Title IV funds.
Repeat Finding: No
Recommendation: We recommend the University implement additional internal controls to ensure
proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to
separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing
training should be provided to financial aid staff on the importance of internal controls and compliance
with Title IV regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.