Audit 366719

Finding 2024-002: Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program. Compliance Requirements: Eligibility Criteria: (34 CFR 690.62(a)) The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. Condition: For the year ended May 31, 2024, we reviewed general eligibility requirements for students who received Title IV program funds and noted two (2) instances where a student received Federal Pell Grant Program funds during the audit period in excess of the amount published by the Secretary. Cause: No cause could be determined. Effect: Students received more Federal Pell Grant program funds than allowed. Questioned Costs: $1,809 in 23-24 Federal Pell Grant program funds. Context: We tested forty (40) randomly selected student files totaling $75,687 Federal Pell Grant Program funds from a population of $2,323,602 Federal Pell Grant Program funds and found two (2) instances of noncompliance in the amount of $1,809. Student #E1 – The student received $2,658 in 23-24 Federal Pell Grant program funds. The student was eligible for $1,773 in 23-24 Federal Pell Grant program funds, resulting in an $885 overaward in 23-24 Federal Pell Grant program funds. For the Sprint 2024 semester the student was awarded based on a full-time status while only enrolled half-time. Student #E30 - The student received $7,395 in 23-24 Federal Pell Grant program funds. The student was eligible for $6,471 in 23-24 Federal Pell Grant program funds, resulting in a $924 overaward in 23-24 Federal Pell Grant program funds. For the Sprint 2024 semester the student was awarded based on a full-time status while only attending enough classes to be considered enrolled three-quarter time. Repeat Finding: Not a repeat finding. Recommendation: We recommend management review and revise controls over student eligibility to determine students had begun attendance in enough classes to maintain the enrollment status their Federal Pell Grant program funds were awarded on. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. The Financial Aid module Jenzabar Financial Aid has been configured by the Director of Financial Aid with a group process to identify enrollment level changes. This process is programmed to adjust the student scheduled Pell to reflect the updated Pell amount based on the Pell table. This process will reduce the Pell amount if the hours adjust down even when the Pell has already disbursed. This process will also increase the Pell when the hours increase. This process is on a scheduler that runs daily. Planned Implementation Date of Corrective Action: This process was created and implemented 10/01/2024. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid

Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Compliance Requirements: Return of Title IV Funds Criteria: (34 CFR 668.22(a)(1)) When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section. Condition: For the year ended May 31, 2024, we reviewed return of title IV funds requirements for students who received title IV program funds and withdrew from the institution during the audit period and noted one (1) instance where the institution used the incorrect calculation resulting in funds due to the Department and two (2) instances where the institution used the incorrect calculation resulting in too much funds returned to the department. Cause: No cause could be determined. Effect: Students retained the incorrect amount of title IV funds after a withdraw. Questioned Costs: $2,733 in 23-24 Unsubsidized Federal Direct Loan program funds under refunded to the department and $50 in 23-24 Federal Pell Grant Program Funds over refunded to the department. Context: We tested six (6) randomly selected student files totaling $3,556 Title IV funds returned to the department from a population of $70,058 Title IV funds returned to the department and found one (1) instance where the institution used the incorrect calculation resulting in funds due to the Department and two (2) instances where the institution used the incorrect calculation resulting in too many funds returned to the department. Student #E35 – The student withdrew during the Spring 2024 term and the institution returned $0 23-24 Unsubsidized Federal Direct Loan program funds. The institution should have returned $2,733 in 23-24 Unsubsidized Federal Direct Loan program funds. The institution used a withdrawal date of April 3, 2024, in the return of title IV calculation and should have used the withdrawal date of March 10, 2024, resulting in additional funds to be returned to the department in the amount of $2,733 23-24 Unsubsidized Federal Direct Loan program funds. Student #E39 - The student withdrew during the Fall 2023 term and the institution returned $1,499 23-24 Federal Pell Grant Program funds. The institution should have returned $1,449 in 23-24 Federal Pell Grant Program funds. The institution’s calculation used 112 total days in their return of title IV funds calculation and should have used 103 total days resulting in too many funds returned to the department in the amount of $50 23-24 Federal Pell Grant Program funds. Student #E40 - The student withdrew during the Fall 2023 term and the institution returned $3,252 23-24 Federal Pell Grant Program funds. The institution should have returned $3,083 23- 24 Unsubsidized Federal Direct Loan program funds. The institution used 108 days in their return of title IV funds calculation and should have used 103 break days resulting in too many funds returned to the department in the amount of $169 23-24 Federal Pell Grant Program funds. Repeat Finding: Not a repeat finding. Recommendation: We recommend management return the funds in question and review and revise controls over student withdrawals to ensure the information used in the calculation is correct. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. Thomas University Financial Aid office has an add and drop Report process that runs every day to identify changes in enrollment. Jenzabar has intergraded process that updates the R2T4 withdraw date based on the date input by the Registrar as the Last Date of Attendance according to the Withdraw Record. All Withdraw Records are shared with Financial Aid and the dates are reviewed for accuracy prior to completing calculation. Students are identified as Online or On-Campus students determined by Site. Based on the students’ Site, the number of break days are entered. Jenzabar automatically adjusts any award determined by the calculation process built in Jenzabar. Planned Implementation Date of Corrective Action: This process was created and implemented February 5, 2025. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid

Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Compliance Requirements: Return of Title IV Funds Criteria: (34 CFR 668.22(a)(1)) When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section. Condition: For the year ended May 31, 2024, we reviewed return of title IV funds requirements for students who received title IV program funds and withdrew from the institution during the audit period and noted one (1) instance where the institution used the incorrect calculation resulting in funds due to the Department and two (2) instances where the institution used the incorrect calculation resulting in too much funds returned to the department. Cause: No cause could be determined. Effect: Students retained the incorrect amount of title IV funds after a withdraw. Questioned Costs: $2,733 in 23-24 Unsubsidized Federal Direct Loan program funds under refunded to the department and $50 in 23-24 Federal Pell Grant Program Funds over refunded to the department. Context: We tested six (6) randomly selected student files totaling $3,556 Title IV funds returned to the department from a population of $70,058 Title IV funds returned to the department and found one (1) instance where the institution used the incorrect calculation resulting in funds due to the Department and two (2) instances where the institution used the incorrect calculation resulting in too many funds returned to the department. Student #E35 – The student withdrew during the Spring 2024 term and the institution returned $0 23-24 Unsubsidized Federal Direct Loan program funds. The institution should have returned $2,733 in 23-24 Unsubsidized Federal Direct Loan program funds. The institution used a withdrawal date of April 3, 2024, in the return of title IV calculation and should have used the withdrawal date of March 10, 2024, resulting in additional funds to be returned to the department in the amount of $2,733 23-24 Unsubsidized Federal Direct Loan program funds. Student #E39 - The student withdrew during the Fall 2023 term and the institution returned $1,499 23-24 Federal Pell Grant Program funds. The institution should have returned $1,449 in 23-24 Federal Pell Grant Program funds. The institution’s calculation used 112 total days in their return of title IV funds calculation and should have used 103 total days resulting in too many funds returned to the department in the amount of $50 23-24 Federal Pell Grant Program funds. Student #E40 - The student withdrew during the Fall 2023 term and the institution returned $3,252 23-24 Federal Pell Grant Program funds. The institution should have returned $3,083 23- 24 Unsubsidized Federal Direct Loan program funds. The institution used 108 days in their return of title IV funds calculation and should have used 103 break days resulting in too many funds returned to the department in the amount of $169 23-24 Federal Pell Grant Program funds. Repeat Finding: Not a repeat finding. Recommendation: We recommend management return the funds in question and review and revise controls over student withdrawals to ensure the information used in the calculation is correct. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. Thomas University Financial Aid office has an add and drop Report process that runs every day to identify changes in enrollment. Jenzabar has intergraded process that updates the R2T4 withdraw date based on the date input by the Registrar as the Last Date of Attendance according to the Withdraw Record. All Withdraw Records are shared with Financial Aid and the dates are reviewed for accuracy prior to completing calculation. Students are identified as Online or On-Campus students determined by Site. Based on the students’ Site, the number of break days are entered. Jenzabar automatically adjusts any award determined by the calculation process built in Jenzabar. Planned Implementation Date of Corrective Action: This process was created and implemented February 5, 2025. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid