2024-004 –Satisfactory Academic Progress Policy (Significant Deficiency) Department of Education, SFA Cluster, Eligibility Criteria: In accordance with 34 CFR 668.34(a), an institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. A student placed on academic probation may receive Title IV, HEA program funds for one payment period. At the end of one payment period on financial aid probation, the student must meet the institution's satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further Title IV, HEA program funds. Condition: Our review of 26 student files disclosed that one student was placed on academic probation after fall 2023 semester and received Pell for spring 2024 semester. The student did not meet satisfactory academic progress standards at the end of spring 2024 semester, however, the student received Pell for summer semester 2024. Cause: Controls are not functioning properly. Effect: Title IV program funds were awarded to a student who was not eligible to receive such funds. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University review and update its policies to ensure that the University’s Satisfactory Academic Progress policy is enforced. Management Response: The University acknowledges the oversight in the enforcement of its Satisfactory Academic Progress (SAP) policy and has taken corrective action to address the deficiency. Specifically, the Financial Aid Office has conducted a comprehensive review of SAP monitoring procedures to ensure full compliance with federal regulations under 34 CFR 668.34. Corrective steps taken include: 1) Policy Clarification and Staff Training: The SAP policy has been reviewed and clarified to emphasize the requirement that a student failing to meet SAP after one payment period on financial aid probation is no longer eligible for Title IV funds unless they meet the conditions of an approved academic plan. Targeted training was delivered to financial aid counselors and compliance staff to reinforce correct application of SAP policies and documentation protocols. 2) Automated SAP Compliance Flag: An automated flag has been integrated into the student information system to alert staff when a student has reached the end of a probation period. This flag prevents Title IV disbursement until a manual review confirms eligibility based on SAP or academic plan compliance. 3)Ongoing Monitoring and Quality Assurance: At the conclusion of each academic term, the University runs comprehensive SAP reports to identify all students who have either regained eligibility, remained on SAP, or have newly been placed on SAP status. The student information system is configured to automatically flag these students and restrict Title IV disbursements through system-based controls in the auto-packaging process, thereby preventing ineligible aid disbursements and ensuring compliance with federal regulations.
2024-005 – Over Award of Federal Pell Grant Program Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: In accordance with 34 CFR 668.32, a student is eligible to receive Title IV, HEA program assistance if the student meets all of the requirements in 34 CFR 668.32 paragraphs (a) through (m). 34 CFR 668.32(a)(1)(i) requires the student to be a regular student enrolled, or accepted for enrollment, in an eligible program at an eligible institution. Condition: Of 26 students tested for eligibility, one student received Title IV, HEA program assistance for a semester that the student was not enrolled in. Cause: Controls are not functioning properly. Effect: Title IV program funds were awarded to a student who was not eligible to receive such funds. Repeat Finding from a Prior Year: This is a repeat of findings 2023-001 and 2022-001. Recommendation: We recommend the University review and update its procedures to ensure that Title IV funds are awarded properly. Management Response: The University acknowledges the over-award of Title IV funds due to disbursement for a student who was not enrolled during the term in question. In response, the University has strengthened its internal controls to ensure that federal aid is awarded and disbursed only to students who meet all eligibility criteria as outlined in 34 CFR 668.32. Corrective actions taken include: 1) System Validation Enhancements: The student information system has been updated to include enhanced enrollment validation checks before the release of Title IV funds. Title IV disbursements are now restricted to students with confirmed active enrollment in eligible programs for the applicable term. This is enforced through automated disbursement blocks that are triggered when enrollment data is missing or inconsistent. 2) Pre-Disbursement Review Process: A pre-disbursement verification step has been implemented, requiring financial aid staff to confirm active enrollment statuses before releasing funds. 3) Staff Training: Targeted training has been provided to financial aid staff on Title IV enrollment eligibility requirements.
2024-003 – Cash Management (Significant Deficiency) Department of Education, SFA Cluster, Cash Management Criteria: In accordance with 34 CFR 668.164, an institution submits a drawdown request for funds utilizing ED’s electronic grants management system that may not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The institution must disburse the requested funds as soon as administratively possible, but no later than three business days following receipt of those funds from ED. Any funds not disbursed by the end of the third business day are considered excess cash. Condition: A sample of twenty-six students were tested for timely distribution of federal student aid funds. Aid was distributed more than three business days after funds were received from ED for all students tested. Cause: Lack of controls over cash management. Effect: Excess federal cash retained by the institution. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University implement appropriate training regarding compliance regulations into the employee onboarding process and thereafter for applicable employees. In addition, we recommend the University implements timely review procedures to ensure that any overdrawn funds are returned within the tolerance period. Management Response: The University acknowledges the deficiency in the timely disbursement of Title IV funds and has taken immediate corrective action to strengthen cash management controls. Specifically, the Financial Aid Office and the Business Office collaborated to revise internal procedures to ensure that federal funds are disbursed within three business days of receipt from the U.S. Department of Education. Effective 7/16/2025, a new standard operating procedure (SOP) was implemented, which includes: 1) Weekly reconciliation between Campus Anyware and G5 drawdowns to track the timing of funds received and disbursed. 2) Mandatory compliance training on federal cash management regulations for all financial aid and student accounts staff, both during onboarding and annually thereafter. 3) Monthly internal audits to review disbursement timelines and identify exceptions. Additionally, any funds inadvertently held beyond the three-day window are now promptly returned to G5 within the regulatory tolerance period.
2023-006 – Last Date of Attendance at an Academically Related Activity (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdrawal; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; or (4-6) other special circumstances as documented by the institution. An institution that is not required to take attendance at an academically related activity may use, as the withdrawal date, the last date of attendance at an academically related activity as documented by the institution (34 CFR 668.22(c)). Condition: From a population of 163 students that officially or unofficially withdrew, we tested nineteen students and noted that documentation of the last date of attendance could not be provided for six students that unofficially withdrew and six students that officially withdrew. Cause: Controls are not functioning properly. Effect: Since documentation of the last date of attendance could not be provided, it could not be determined whether students that unofficially withdrew attended through the end of the period or students that officially withdrew had the correct date of last attendance. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University implement a policy to document the last date of attendance for students that unofficially withdrawal. In addition, we recommend the University maintain student-initiated withdrawal documentation for students that officially withdrawal. Management Response: The University acknowledges the deficiency in documenting the last dates of attendance for students who withdrew and has taken corrective actions to strengthen compliance with 34 CFR 668.22(c). To address this issue, the following steps have been implemented: 1)Revised Withdrawal Procedures: The University has formalized and updated its withdrawal procedures to require consistent documentation of the last date of attendance at an academically related activity for both official and unofficial withdrawals. Faculty are now required to report the last date a student participated in an academically related activity when submitting final grades or withdrawal notifications. 2) Mandatory Faculty Participation: Training will be provided to faculty and department chairs, emphasizing the importance of recording the last date of attendance for all students who cease attendance. The Registrar’s Office will incorporate this requirement into end-of-term processes and will enforce compliance before grade submission is finalized. 3) Retention of Student-Initiated Withdrawal Forms: A centralized and secure repository has been implemented to retain all student-initiated withdrawal requests. The Registrar’s Office is now responsible for maintaining this documentation and conducting periodic audits to ensure proper archiving. 4) Ongoing Monitoring: The Financial Aid and Registrar’s Offices will initiate a joint term-by-term reconciliation process to identify discrepancies in withdrawal reporting and verify the completeness of documentation.
2024-007 – Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: According to 2 CFR 200.210(b), a recipient of Federal awards is required to prepare a SEFA for the period covered by the entity’s financial statement which must include the total Federal awards expended. In addition, 2 CFR 200.303 requires non-Federal entities to, among other things, establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Effective internal controls should include procedures to ensure expenditures are properly reported on the SEFA. In addition to providing an accurate SEFA, an organization must also be able to demonstrate that it has a system of internal control that supports the preparation of the SEFA. Condition: The University did not have an adequate process in place to prepare and review its SEFA. Cause: The University’s internal control process for preparing the SEFA did not include review and approval of the SEFA prior to providing it to the auditor. Effect: Failure to accurately report federal expenditures on the SEFA could result in noncompliance with federal regulations. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University establish, document, and maintain effective internal controls over the preparation of the SEFA. At a minimum, an organization should be able to show documentation that the SEFA was reviewed and approved by an individual who was not directly involved with the initial preparation of the SEFA. The review process should include checking both the reported expenditures of federal awards and the assistance listing numbers reported for each grant program. Management Response: The University acknowledges the identified deficiency in the internal control process related to the preparation and review of the Schedule of Expenditures of Federal Awards (SEFA). In response, the University has implemented a formalized and documented process to ensure the SEFA is accurately prepared, thoroughly reviewed, and approved in compliance with 2 CFR 200.210(b) and 2 CFR 200.303. The corrective actions taken include: 1) Independent Review and Approval: The SEFA is now subject to a formal review and approval process by an individual who is independent of the initial preparation. This review involves verifying the accuracy of reported expenditures, confirming the proper listing of assistance numbers (CFDA numbers), and ensuring that all program titles match the federal award documentation. 2) Internal Control Documentation: The University has documented its SEFA preparation and review procedures as part of its internal control framework. This documentation includes roles, responsibilities, timelines, and sign-off requirements to provide an audit trail for compliance verification. 3) Staff Training and Cross-Departmental Coordination: Staff involved in grants accounting and financial reporting will receive targeted training on SEFA requirements. Additionally, coordination among the Financial Aid Office and Finance Office has been strengthened to ensure the complete and accurate sharing of data related to federal award expenditures.
2024-004 –Satisfactory Academic Progress Policy (Significant Deficiency) Department of Education, SFA Cluster, Eligibility Criteria: In accordance with 34 CFR 668.34(a), an institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. A student placed on academic probation may receive Title IV, HEA program funds for one payment period. At the end of one payment period on financial aid probation, the student must meet the institution's satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further Title IV, HEA program funds. Condition: Our review of 26 student files disclosed that one student was placed on academic probation after fall 2023 semester and received Pell for spring 2024 semester. The student did not meet satisfactory academic progress standards at the end of spring 2024 semester, however, the student received Pell for summer semester 2024. Cause: Controls are not functioning properly. Effect: Title IV program funds were awarded to a student who was not eligible to receive such funds. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University review and update its policies to ensure that the University’s Satisfactory Academic Progress policy is enforced. Management Response: The University acknowledges the oversight in the enforcement of its Satisfactory Academic Progress (SAP) policy and has taken corrective action to address the deficiency. Specifically, the Financial Aid Office has conducted a comprehensive review of SAP monitoring procedures to ensure full compliance with federal regulations under 34 CFR 668.34. Corrective steps taken include: 1) Policy Clarification and Staff Training: The SAP policy has been reviewed and clarified to emphasize the requirement that a student failing to meet SAP after one payment period on financial aid probation is no longer eligible for Title IV funds unless they meet the conditions of an approved academic plan. Targeted training was delivered to financial aid counselors and compliance staff to reinforce correct application of SAP policies and documentation protocols. 2) Automated SAP Compliance Flag: An automated flag has been integrated into the student information system to alert staff when a student has reached the end of a probation period. This flag prevents Title IV disbursement until a manual review confirms eligibility based on SAP or academic plan compliance. 3)Ongoing Monitoring and Quality Assurance: At the conclusion of each academic term, the University runs comprehensive SAP reports to identify all students who have either regained eligibility, remained on SAP, or have newly been placed on SAP status. The student information system is configured to automatically flag these students and restrict Title IV disbursements through system-based controls in the auto-packaging process, thereby preventing ineligible aid disbursements and ensuring compliance with federal regulations.
2024-005 – Over Award of Federal Pell Grant Program Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: In accordance with 34 CFR 668.32, a student is eligible to receive Title IV, HEA program assistance if the student meets all of the requirements in 34 CFR 668.32 paragraphs (a) through (m). 34 CFR 668.32(a)(1)(i) requires the student to be a regular student enrolled, or accepted for enrollment, in an eligible program at an eligible institution. Condition: Of 26 students tested for eligibility, one student received Title IV, HEA program assistance for a semester that the student was not enrolled in. Cause: Controls are not functioning properly. Effect: Title IV program funds were awarded to a student who was not eligible to receive such funds. Repeat Finding from a Prior Year: This is a repeat of findings 2023-001 and 2022-001. Recommendation: We recommend the University review and update its procedures to ensure that Title IV funds are awarded properly. Management Response: The University acknowledges the over-award of Title IV funds due to disbursement for a student who was not enrolled during the term in question. In response, the University has strengthened its internal controls to ensure that federal aid is awarded and disbursed only to students who meet all eligibility criteria as outlined in 34 CFR 668.32. Corrective actions taken include: 1) System Validation Enhancements: The student information system has been updated to include enhanced enrollment validation checks before the release of Title IV funds. Title IV disbursements are now restricted to students with confirmed active enrollment in eligible programs for the applicable term. This is enforced through automated disbursement blocks that are triggered when enrollment data is missing or inconsistent. 2) Pre-Disbursement Review Process: A pre-disbursement verification step has been implemented, requiring financial aid staff to confirm active enrollment statuses before releasing funds. 3) Staff Training: Targeted training has been provided to financial aid staff on Title IV enrollment eligibility requirements.
2024-003 – Cash Management (Significant Deficiency) Department of Education, SFA Cluster, Cash Management Criteria: In accordance with 34 CFR 668.164, an institution submits a drawdown request for funds utilizing ED’s electronic grants management system that may not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The institution must disburse the requested funds as soon as administratively possible, but no later than three business days following receipt of those funds from ED. Any funds not disbursed by the end of the third business day are considered excess cash. Condition: A sample of twenty-six students were tested for timely distribution of federal student aid funds. Aid was distributed more than three business days after funds were received from ED for all students tested. Cause: Lack of controls over cash management. Effect: Excess federal cash retained by the institution. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University implement appropriate training regarding compliance regulations into the employee onboarding process and thereafter for applicable employees. In addition, we recommend the University implements timely review procedures to ensure that any overdrawn funds are returned within the tolerance period. Management Response: The University acknowledges the deficiency in the timely disbursement of Title IV funds and has taken immediate corrective action to strengthen cash management controls. Specifically, the Financial Aid Office and the Business Office collaborated to revise internal procedures to ensure that federal funds are disbursed within three business days of receipt from the U.S. Department of Education. Effective 7/16/2025, a new standard operating procedure (SOP) was implemented, which includes: 1) Weekly reconciliation between Campus Anyware and G5 drawdowns to track the timing of funds received and disbursed. 2) Mandatory compliance training on federal cash management regulations for all financial aid and student accounts staff, both during onboarding and annually thereafter. 3) Monthly internal audits to review disbursement timelines and identify exceptions. Additionally, any funds inadvertently held beyond the three-day window are now promptly returned to G5 within the regulatory tolerance period.
2023-006 – Last Date of Attendance at an Academically Related Activity (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdrawal; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; or (4-6) other special circumstances as documented by the institution. An institution that is not required to take attendance at an academically related activity may use, as the withdrawal date, the last date of attendance at an academically related activity as documented by the institution (34 CFR 668.22(c)). Condition: From a population of 163 students that officially or unofficially withdrew, we tested nineteen students and noted that documentation of the last date of attendance could not be provided for six students that unofficially withdrew and six students that officially withdrew. Cause: Controls are not functioning properly. Effect: Since documentation of the last date of attendance could not be provided, it could not be determined whether students that unofficially withdrew attended through the end of the period or students that officially withdrew had the correct date of last attendance. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University implement a policy to document the last date of attendance for students that unofficially withdrawal. In addition, we recommend the University maintain student-initiated withdrawal documentation for students that officially withdrawal. Management Response: The University acknowledges the deficiency in documenting the last dates of attendance for students who withdrew and has taken corrective actions to strengthen compliance with 34 CFR 668.22(c). To address this issue, the following steps have been implemented: 1)Revised Withdrawal Procedures: The University has formalized and updated its withdrawal procedures to require consistent documentation of the last date of attendance at an academically related activity for both official and unofficial withdrawals. Faculty are now required to report the last date a student participated in an academically related activity when submitting final grades or withdrawal notifications. 2) Mandatory Faculty Participation: Training will be provided to faculty and department chairs, emphasizing the importance of recording the last date of attendance for all students who cease attendance. The Registrar’s Office will incorporate this requirement into end-of-term processes and will enforce compliance before grade submission is finalized. 3) Retention of Student-Initiated Withdrawal Forms: A centralized and secure repository has been implemented to retain all student-initiated withdrawal requests. The Registrar’s Office is now responsible for maintaining this documentation and conducting periodic audits to ensure proper archiving. 4) Ongoing Monitoring: The Financial Aid and Registrar’s Offices will initiate a joint term-by-term reconciliation process to identify discrepancies in withdrawal reporting and verify the completeness of documentation.
2024-007 – Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: According to 2 CFR 200.210(b), a recipient of Federal awards is required to prepare a SEFA for the period covered by the entity’s financial statement which must include the total Federal awards expended. In addition, 2 CFR 200.303 requires non-Federal entities to, among other things, establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Effective internal controls should include procedures to ensure expenditures are properly reported on the SEFA. In addition to providing an accurate SEFA, an organization must also be able to demonstrate that it has a system of internal control that supports the preparation of the SEFA. Condition: The University did not have an adequate process in place to prepare and review its SEFA. Cause: The University’s internal control process for preparing the SEFA did not include review and approval of the SEFA prior to providing it to the auditor. Effect: Failure to accurately report federal expenditures on the SEFA could result in noncompliance with federal regulations. Repeat Finding from a Prior Year: Not a repeat finding. Recommendation: We recommend the University establish, document, and maintain effective internal controls over the preparation of the SEFA. At a minimum, an organization should be able to show documentation that the SEFA was reviewed and approved by an individual who was not directly involved with the initial preparation of the SEFA. The review process should include checking both the reported expenditures of federal awards and the assistance listing numbers reported for each grant program. Management Response: The University acknowledges the identified deficiency in the internal control process related to the preparation and review of the Schedule of Expenditures of Federal Awards (SEFA). In response, the University has implemented a formalized and documented process to ensure the SEFA is accurately prepared, thoroughly reviewed, and approved in compliance with 2 CFR 200.210(b) and 2 CFR 200.303. The corrective actions taken include: 1) Independent Review and Approval: The SEFA is now subject to a formal review and approval process by an individual who is independent of the initial preparation. This review involves verifying the accuracy of reported expenditures, confirming the proper listing of assistance numbers (CFDA numbers), and ensuring that all program titles match the federal award documentation. 2) Internal Control Documentation: The University has documented its SEFA preparation and review procedures as part of its internal control framework. This documentation includes roles, responsibilities, timelines, and sign-off requirements to provide an audit trail for compliance verification. 3) Staff Training and Cross-Departmental Coordination: Staff involved in grants accounting and financial reporting will receive targeted training on SEFA requirements. Additionally, coordination among the Financial Aid Office and Finance Office has been strengthened to ensure the complete and accurate sharing of data related to federal award expenditures.