III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
III. Federal Awards Findings and Questioned Costs FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063,84.268, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary (Secretary of the Department of Education), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution 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. Condition and context: A sample of 35 students who possessed status changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 865 total status changes. Student record changes were compared to updated enrollment reports sent to the Secretary. We noted that of 35 students sampled and tested, three student withdrawals and one graduated student were not reported timely. We did not expand our sample. Questioned costs: None Effect: The University did not report all student status changes in a timely manner. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. Cause: A reconciliation process has not been designed or implemented to ensure that all status changes have been captured from the system of record to the National Student Loan Data System (NSLDS). Repeat finding: Yes, 2024-001. Recommendation: We recommend the University implements a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.379, Federal Program Name: Student Financial Assistance Cluster Award Year: 2024-2025 Criteria: Per 34 CFR §§ 682.605 and 685.305, institutions participating in Title IV programs are required to determine the withdrawal date of a student who has unofficially withdrawn no later than 30 days after the earlier of the following: • The end of the payment period or period of enrollment, • The end of the academic year, or • The end of the student’s educational program. This requirement applies to both attendance-taking and non-attendance-taking institutions. While the method for determining the withdrawal date may differ (e.g., based on the last academically related activity), the timeframe for identifying the unofficial withdrawal remains consistent. In addition, under 34 CFR §668.22, institutions are responsible for calculating the amount of earned Title IV aid based on the student’s withdrawal date. If the student did not earn 100% of the aid disbursed, the unearned portion must be returned by the institution within the timelines prescribed by federal regulations. Condition and Context: A sample of 14 students who withdrew during the year and were recipients of Title IV funding were selected for testing. Our sample was selected using a random and judgmental sampling methodology, from a population of 91 total withdrawals. Two of the unofficial withdrawal students selected for testing we’re not identified as unofficial withdrawals for approximately 88 and 102 days after the last day or the related term which is considered late. Once identified by the University, the calculation was performed, and the funds were returned to the Department of Education in the amount of $9,975. Questioned costs: No Effect: The University did not identify and report unofficial withdrawals within the required timeframe. As a result, the students’ enrollment statuses may have been inaccurately reflected in reporting systems used by the Department of Education, the Federal Direct Loan Program, loan servicers, and other institutions. This could lead to additional delayed return of title IV funds and potential noncompliance with federal financial aid regulations. Cause: The University’s current processes for identifying unofficial withdrawals was not designed to ensure timely detection and reporting within the federally required timeframe. Repeat finding: No Recommendation: We recommend the University enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support timeliness of federal compliance.