2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. It has been determined that where Anthology reported enrollment based off of programs version instead student types that the export to Clearinghouse did not pull correctly for every student because of multiple program versions that a student could have active. The institution has resolved this issue with the conversion back to Colleague which pulls student types.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Statement of Condition: During the audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: The University concurs with this finding. Due to changeover in staffing and transition of systems, the data and personnel were limited to uploading the documentation in a timely manner. Now that majority of transition has occurred back to colleague, the system conversion should no longer be an issue as of this point forward. As for staffing personnel, the Director of Financial Aid shall upload the data to clearinghouse. Any further transition, and the Associate Director of Financial Aid shall immediately assume the responsibility of uploading the data upon notice of changeover of personnel.
2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 668.22(c) a student's 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 withdraw; (3) if the student ceases attendance without providing official notification, the mid-point of the payment period; (4) if the institution determines that a student did not begin the institution's withdrawal process or otherwise provide official notification to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student's control, the date that the institution determines is related to that circumstance; (5) If a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if a student takes a leave of absence that does not meet certain requirements, the date that the student began the leave of absence. Statement of Condition: During the audit, it was noted that the University reported the incorrect date to NSLDS for the withdrawal date. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 8, indicating an error rate of 20.00%. Cause and Effect: Due to lapses in communication between departments and misunderstanding of the guidance for NSLDS reporting, the University reported the incorrect withdrawal date in some instances, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal date is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Despite the withdrawal date being placed in Anthology, the status date that the withdrawal date was input was sent to clearinghouse instead of the true withdrawal date. Tusculum University has since switched back to Colleague which submit the true withdrawal date when exporting the data to upload to clearinghouse.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. It has been determined that where Anthology reported enrollment based off of programs version instead student types that the export to Clearinghouse did not pull correctly for every student because of multiple program versions that a student could have active. The institution has resolved this issue with the conversion back to Colleague which pulls student types.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Statement of Condition: During the audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: The University concurs with this finding. Due to changeover in staffing and transition of systems, the data and personnel were limited to uploading the documentation in a timely manner. Now that majority of transition has occurred back to colleague, the system conversion should no longer be an issue as of this point forward. As for staffing personnel, the Director of Financial Aid shall upload the data to clearinghouse. Any further transition, and the Associate Director of Financial Aid shall immediately assume the responsibility of uploading the data upon notice of changeover of personnel.
2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 668.22(c) a student's 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 withdraw; (3) if the student ceases attendance without providing official notification, the mid-point of the payment period; (4) if the institution determines that a student did not begin the institution's withdrawal process or otherwise provide official notification to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student's control, the date that the institution determines is related to that circumstance; (5) If a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if a student takes a leave of absence that does not meet certain requirements, the date that the student began the leave of absence. Statement of Condition: During the audit, it was noted that the University reported the incorrect date to NSLDS for the withdrawal date. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 8, indicating an error rate of 20.00%. Cause and Effect: Due to lapses in communication between departments and misunderstanding of the guidance for NSLDS reporting, the University reported the incorrect withdrawal date in some instances, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal date is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Despite the withdrawal date being placed in Anthology, the status date that the withdrawal date was input was sent to clearinghouse instead of the true withdrawal date. Tusculum University has since switched back to Colleague which submit the true withdrawal date when exporting the data to upload to clearinghouse.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. It has been determined that where Anthology reported enrollment based off of programs version instead student types that the export to Clearinghouse did not pull correctly for every student because of multiple program versions that a student could have active. The institution has resolved this issue with the conversion back to Colleague which pulls student types.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Statement of Condition: During the audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: The University concurs with this finding. Due to changeover in staffing and transition of systems, the data and personnel were limited to uploading the documentation in a timely manner. Now that majority of transition has occurred back to colleague, the system conversion should no longer be an issue as of this point forward. As for staffing personnel, the Director of Financial Aid shall upload the data to clearinghouse. Any further transition, and the Associate Director of Financial Aid shall immediately assume the responsibility of uploading the data upon notice of changeover of personnel.
2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 668.22(c) a student's 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 withdraw; (3) if the student ceases attendance without providing official notification, the mid-point of the payment period; (4) if the institution determines that a student did not begin the institution's withdrawal process or otherwise provide official notification to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student's control, the date that the institution determines is related to that circumstance; (5) If a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if a student takes a leave of absence that does not meet certain requirements, the date that the student began the leave of absence. Statement of Condition: During the audit, it was noted that the University reported the incorrect date to NSLDS for the withdrawal date. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 8, indicating an error rate of 20.00%. Cause and Effect: Due to lapses in communication between departments and misunderstanding of the guidance for NSLDS reporting, the University reported the incorrect withdrawal date in some instances, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal date is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Despite the withdrawal date being placed in Anthology, the status date that the withdrawal date was input was sent to clearinghouse instead of the true withdrawal date. Tusculum University has since switched back to Colleague which submit the true withdrawal date when exporting the data to upload to clearinghouse.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. It has been determined that where Anthology reported enrollment based off of programs version instead student types that the export to Clearinghouse did not pull correctly for every student because of multiple program versions that a student could have active. The institution has resolved this issue with the conversion back to Colleague which pulls student types.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Statement of Condition: During the audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: The University concurs with this finding. Due to changeover in staffing and transition of systems, the data and personnel were limited to uploading the documentation in a timely manner. Now that majority of transition has occurred back to colleague, the system conversion should no longer be an issue as of this point forward. As for staffing personnel, the Director of Financial Aid shall upload the data to clearinghouse. Any further transition, and the Associate Director of Financial Aid shall immediately assume the responsibility of uploading the data upon notice of changeover of personnel.
2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 668.22(c) a student's 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 withdraw; (3) if the student ceases attendance without providing official notification, the mid-point of the payment period; (4) if the institution determines that a student did not begin the institution's withdrawal process or otherwise provide official notification to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student's control, the date that the institution determines is related to that circumstance; (5) If a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if a student takes a leave of absence that does not meet certain requirements, the date that the student began the leave of absence. Statement of Condition: During the audit, it was noted that the University reported the incorrect date to NSLDS for the withdrawal date. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 8, indicating an error rate of 20.00%. Cause and Effect: Due to lapses in communication between departments and misunderstanding of the guidance for NSLDS reporting, the University reported the incorrect withdrawal date in some instances, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal date is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Despite the withdrawal date being placed in Anthology, the status date that the withdrawal date was input was sent to clearinghouse instead of the true withdrawal date. Tusculum University has since switched back to Colleague which submit the true withdrawal date when exporting the data to upload to clearinghouse.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.
2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.
2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.