Audit 36678

FY End
2022-06-30
Total Expended
$37.60M
Findings
30
Programs
7
Organization: Stevenson University, Inc. (MD)
Year: 2022 Accepted: 2023-03-20
Auditor: Bdo USA LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
32707 2022-001 - - E
32708 2022-002 - - L
34991 2022-003 - Yes N
34992 2022-005 - Yes N
34993 2022-001 - - E
34994 2022-002 - - L
34995 2022-003 - Yes N
34996 2022-001 - - E
34997 2022-003 - Yes N
34998 2022-005 - Yes N
34999 2022-001 - - E
35000 2022-003 - Yes N
35001 2022-004 Significant Deficiency Yes N
35002 2022-005 - Yes N
35003 2022-006 - - L
609149 2022-001 - - E
609150 2022-002 - - L
611433 2022-003 - Yes N
611434 2022-005 - Yes N
611435 2022-001 - - E
611436 2022-002 - - L
611437 2022-003 - Yes N
611438 2022-001 - - E
611439 2022-003 - Yes N
611440 2022-005 - Yes N
611441 2022-001 - - E
611442 2022-003 - Yes N
611443 2022-004 Significant Deficiency Yes N
611444 2022-005 - Yes N
611445 2022-006 - - L

Contacts

Name Title Type
CVFMED5XEAG7 Mary Beth Schwenke Auditee
4433342050 Michael Dannar Auditor
No contacts on file

Notes to SEFA

Title: Basis of Accounting Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting as more fully described in Note 1 to the Universitys consolidated financial statements, which is in accordance with the Uniform Guidance. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. Te accompanying schedule of expenditures of federal awards (the Schedule) presents the expenditures of federal awards of Stevenson University (the University) and is presented on the accrual basis of accounting, which is consistent with the consolidated financial statements. The Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the University. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the University and agencies and departments of the federal government and all subawards made to the University by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The awards are classified into program categories in accordance with the provisions of Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Expenditures for federal student financial aid programs are recognized as incurred and include Federal Pell program grants to students, Federal Direct Loans programs, the federal share of students Federal Supplemental Educational Opportunity Grant program grants and Federal Work Study program earnings, and administrative cost allowances, where applicable. Loans made under the Direct Loan programs are disbursed by the federal government. Expenditures for other federal awards of the University are recognized primarily on the accrual basis of accounting and are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. Expenditures include facilities and administrative costs, related primarily to facilities operation and maintenance and general, divisional, and departmental administrative services, which are allocated as a percentage of direct cost.
Title: Contingency Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting as more fully described in Note 1 to the Universitys consolidated financial statements, which is in accordance with the Uniform Guidance. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. The grant revenue amounts received are subject to audit and adjustment. If any expenditures are disallowed by the grantor agencies as a result of such an audit, any claim for reimbursement to the grantor agencies would become a liability of the University. In the opinion of management, and with the exception of certain findings presented in the accompanying schedule of findings and questioned costs, all grant expenditures are in compliance with the terms of the grant agreements and applicable federal and state laws and regulations.
Title: Federal Student Loan Programs and Related Matters Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting as more fully described in Note 1 to the Universitys consolidated financial statements, which is in accordance with the Uniform Guidance. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimus indirect cost rate allowed under Uniform Guidance. The University is responsible only for the performance of certain administrative duties with respect to the Federal Direct Loan Program (ALN: 84.268), and accordingly these loans are not included in its consolidated financial statements and it is not practical to determine the balance of loans outstanding to students and former students of the University under these programs as of June 30, 2022. The principal amount of loans disbursed was $25,738,385 for the year ended June 30, 2022.

Finding Details

Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? The Fiscal Operations Report and Application to Participate (?FISAP?) is an electronic report submitted annual to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant (?FSEOG?) Program; Part V, Fiscal Operations Report Federal Work-Study (?FWS?) Program; and Part VI, Program Summary for Award Year. Condition: Through our testing, certain errors in key line items of the University?s FISAP were identified. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University incorrectly reported the length/type of longest program in Part I of the FISAP. Additionally, the number of students and amount of FSEOG Funds to disaster-affected students was not properly reported in Part IV of the FISAP. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that key line items containing critical information are properly reported in the FISAP, in accordance with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reporting threshold. Context: For 1 of 8 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. For 1 of 8 students selected for testing, the University did not retain documentation of the student?s or parent?s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? The Fiscal Operations Report and Application to Participate (?FISAP?) is an electronic report submitted annual to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant (?FSEOG?) Program; Part V, Fiscal Operations Report Federal Work-Study (?FWS?) Program; and Part VI, Program Summary for Award Year. Condition: Through our testing, certain errors in key line items of the University?s FISAP were identified. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University incorrectly reported the length/type of longest program in Part I of the FISAP. Additionally, the number of students and amount of FSEOG Funds to disaster-affected students was not properly reported in Part IV of the FISAP. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that key line items containing critical information are properly reported in the FISAP, in accordance with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reporting threshold. Context: For 1 of 8 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. For 1 of 8 students selected for testing, the University did not retain documentation of the student?s or parent?s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain borrowers did not receive a loan disbursement notification or the University was unable to provide a copy of the loan disbursement notification sent to the student. Cause: Administrative oversight and insufficient internal controls with respect to loan disbursement notifications. Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 6 of 25 students selected for testing, the University was unable to provide documentation supporting appropriate loan disbursement notification. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and its internal controls over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reporting threshold. Context: For 1 of 8 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. For 1 of 8 students selected for testing, the University did not retain documentation of the student?s or parent?s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements.
Program Information: COVID-19 Education Stabilization Fund (?ESF?) ? Student Aid Portion (ALN: 84.425E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? Quarterly Public Reporting ? The University is required to publicly post certain information for the Student Aid Portion award on the University?s website in a conspicuous location. Institutions must post certain key line items identified by the ED as critical information directly to their website each calendar quarter, and reports must be updated no later than 10 days after the end of each calendar quarter. Special Reporting ? Annual Reporting ? The ED developed the ESF Data Collection Form that institutions must use to satisfy the annual reporting requirement. The form was required to be submitted to ED via the Annual Report Data Collection System no later than May 6, 2022. Condition: Certain key line items were not correctly reported in the University?s quarterly reports. Additionally, the ESF annual report was not submitted within the required timeframe. Cause: Administrative oversight with respect to quarterly public reporting requirements. Effect or Potential Effect: The University is not in compliance with reporting requirements. Questioned Costs: None. Context: For 2 of 2 quarters selected for testing, certain required key line items for the Student Aid Portion awards reported on the University?s website contained inaccurate information. Additionally, the ESF annual report was not submitted within the required timeframe. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures over quarterly reporting to ensure that all required information is reported accurately, in accordance with federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? The Fiscal Operations Report and Application to Participate (?FISAP?) is an electronic report submitted annual to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant (?FSEOG?) Program; Part V, Fiscal Operations Report Federal Work-Study (?FWS?) Program; and Part VI, Program Summary for Award Year. Condition: Through our testing, certain errors in key line items of the University?s FISAP were identified. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University incorrectly reported the length/type of longest program in Part I of the FISAP. Additionally, the number of students and amount of FSEOG Funds to disaster-affected students was not properly reported in Part IV of the FISAP. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that key line items containing critical information are properly reported in the FISAP, in accordance with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reporting threshold. Context: For 1 of 8 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. For 1 of 8 students selected for testing, the University did not retain documentation of the student?s or parent?s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? The Fiscal Operations Report and Application to Participate (?FISAP?) is an electronic report submitted annual to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant (?FSEOG?) Program; Part V, Fiscal Operations Report Federal Work-Study (?FWS?) Program; and Part VI, Program Summary for Award Year. Condition: Through our testing, certain errors in key line items of the University?s FISAP were identified. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University incorrectly reported the length/type of longest program in Part I of the FISAP. Additionally, the number of students and amount of FSEOG Funds to disaster-affected students was not properly reported in Part IV of the FISAP. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that key line items containing critical information are properly reported in the FISAP, in accordance with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reporting threshold. Context: For 1 of 8 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. For 1 of 8 students selected for testing, the University did not retain documentation of the student?s or parent?s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements.
Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility ? Calculation of Benefits ? Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance (?COA?) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. E. Eligibility ? Federal Pell Grant (Assistance Listing 84.063) ? Each year, based on the maximum Pell Grant established by Congress, the U.S. Department of Education (?ED?) provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their expected family contribution (?EFC?) and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. The steps to determine Pell awards are as follows: (a) Determine the student?s enrollment status, (b) calculate the cost of attendance, (c) determine the annual award, (d) determine the payment period, (e) calculate the payment for the payment periods, and (f) disburse funds at prescribed times. Condition: For certain students identified through our testing, the University did not properly calculate the student?s COA. Additionally, for certain students the University improperly calculated the student?s Pell award. Cause: Administrative oversight with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students? COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions: ? For 2 of 25 students selected for testing, the University did not properly calculate the student?s COA and for 1 of 25 students, the student was disbursed aid in excess of their COA. ? For 1 of 25 students selected for testing, the University did not properly calculate the student?s Pell award. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation or the information could not be provided by the University. Cause: Administrative oversight with respect to verification procedures. Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Unknown. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its policies and procedures and to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain borrowers did not receive a loan disbursement notification or the University was unable to provide a copy of the loan disbursement notification sent to the student. Cause: Administrative oversight and insufficient internal controls with respect to loan disbursement notifications. Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 6 of 25 students selected for testing, the University was unable to provide documentation supporting appropriate loan disbursement notification. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures and its internal controls over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe.
Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amounts to be returned to the ED. Additionally, the University was unable to provide evidence of approval from the borrower prior to making a post-withdrawal disbursement of loan funds. Cause: Administrative oversight with respect to return of Title IV fund calculations and post-withdrawal disbursements. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reporting threshold. Context: For 1 of 8 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. For 1 of 8 students selected for testing, the University did not retain documentation of the student?s or parent?s approval obtained prior to making a post-withdrawal disbursement of loan funds. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, and that adequate records are maintained to support proper procedures for post-withdrawal disbursements.
Program Information: COVID-19 Education Stabilization Fund (?ESF?) ? Student Aid Portion (ALN: 84.425E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? Quarterly Public Reporting ? The University is required to publicly post certain information for the Student Aid Portion award on the University?s website in a conspicuous location. Institutions must post certain key line items identified by the ED as critical information directly to their website each calendar quarter, and reports must be updated no later than 10 days after the end of each calendar quarter. Special Reporting ? Annual Reporting ? The ED developed the ESF Data Collection Form that institutions must use to satisfy the annual reporting requirement. The form was required to be submitted to ED via the Annual Report Data Collection System no later than May 6, 2022. Condition: Certain key line items were not correctly reported in the University?s quarterly reports. Additionally, the ESF annual report was not submitted within the required timeframe. Cause: Administrative oversight with respect to quarterly public reporting requirements. Effect or Potential Effect: The University is not in compliance with reporting requirements. Questioned Costs: None. Context: For 2 of 2 quarters selected for testing, certain required key line items for the Student Aid Portion awards reported on the University?s website contained inaccurate information. Additionally, the ESF annual report was not submitted within the required timeframe. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures over quarterly reporting to ensure that all required information is reported accurately, in accordance with federal regulations.