Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-005-Student Financial Aid Cluster, ALN# 84.268 Compliance Requirement: Eligibility under the Federal Direct Student Loans Program
Criteria: 34 CFR 685.203(d) and (e) specifies the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans.
Condition: Students selected were disbursed loans in excess of the aggregate loan limits.
Cause: Clerical error made by the Student Financial Aid Department.
Effect: The University is not in compliance with aggregate loan limits of the federal direct student loans program.
Questioned Costs: $11,495; on February 24, 2025 the University made adjustments to the related student’s account and reimbursed the over award to the Department of Education.
Context: Three out of twenty-five students selected for testing were disbursed federal direct student loans in excess of aggregate limits.
Recommendation: The University should review its process and policies relating to awarding federal direct student loan funds and implement procedures to prevent the over awarding of federal direct student loans in excess of all loan limits under the Federal Direct Student Loans program.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-005-Student Financial Aid Cluster, ALN# 84.268 Compliance Requirement: Eligibility under the Federal Direct Student Loans Program
Criteria: 34 CFR 685.203(d) and (e) specifies the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans.
Condition: Students selected were disbursed loans in excess of the aggregate loan limits.
Cause: Clerical error made by the Student Financial Aid Department.
Effect: The University is not in compliance with aggregate loan limits of the federal direct student loans program.
Questioned Costs: $11,495; on February 24, 2025 the University made adjustments to the related student’s account and reimbursed the over award to the Department of Education.
Context: Three out of twenty-five students selected for testing were disbursed federal direct student loans in excess of aggregate limits.
Recommendation: The University should review its process and policies relating to awarding federal direct student loan funds and implement procedures to prevent the over awarding of federal direct student loans in excess of all loan limits under the Federal Direct Student Loans program.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003-Student Financial Aid Cluster, ALN#84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The University is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The University does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the University meets some of the seven elements as described in 16 CFR 314.4 (b), the University has yet to establish a formalized written policy.
Effect: The University could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Questioned Costs: None
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, and the University does not have formal written documentation of its program.
Recommendation: The University should implement a written security program that addresses the required elements as described in 16 CFR 314.4 (b).
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-004-Student Financial Aid Cluster, ALN# 84.007, 84.033, 84.063, 84.268, 84.379 Compliance Requirement: Return of Title IV Funds
Criteria: The University’s policy is that computations of refunds of Title IV Funds and withdrawal statements are to be reviewed by someone other than the preparer prior to funds being returned/disbursed.
Condition: The refund of one of the two students selected for testing was incorrectly computed and was disbursed after 45 days from the withdrawal date.
Cause: The University did not have someone independent of the preparer to review withdrawal statements and R2T4s prior to refunds being issued due to staffing turnover and unfilled positions in the student financial aid department during the year ended June 30, 2024.
Effect: Refunds and disbursements to withdrawn students could be computed incorrectly and not within the required time frame.
Questioned Costs: None
Context: Two out of fourteen withdrawn students for the year ended June 30, 2024 were selected for testing. One of the two selected student’s refund was incorrectly computed and refunded after the required time frame.
Recommendation: The University should have return of Title IV funds computations reviewed by someone independent of the person who does the initial computation.
Management Response: The University concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.