Audit 371097

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not submit its next Roster File to NSLDS within 60 days. Condition: The University did not report students’ status changes accurately and within the required timeframe. Cause: Significant turnover of staff in the Registrar’s Office. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: Program Level: Based on a sample of 40 students, 29 students’ enrollment status were not accurately reported to the NSLDS. Program Level: Based on a sample of 40 students, 1 student exceeded the maximum time allowed in the program. Campus Level: Based on a sample of 40 students, 4 students’ selected were not reported to the NSLDS within the required timeframe. Campus Level: Based on a sample of 40 students, 5 students’ enrollment effective date was not correctly reported. Identification of Repeat Finding: This is a repeat of prior year finding 2024-001. Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner. Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified previously; however, the situation was not able to be rectified until well into the 2025 fiscal year. The University has hired new permanent staff, including an experienced registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students within 14 days of the credit being created on the students account. Condition: The University did not return credit balances to students within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances. Questioned Costs: None. Context: Based on a sample of 40 students, 2 students selected had a credit balance that was not returned within the 14-day period. Subsequent to the 14-day period, the credit balances were returned to the students. Identification of Repeat Finding: This is a repeat of prior year finding 2024-002. Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students. Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them twice weekly, with two different staff members cross-trained so that a week is never missed. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. This was identified in the prior year audit, but unfortunately not fixed until well into the 2025 fiscal year.

Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063). Criteria or Specific Requirement: C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: The University had one instance during the year that was identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight. Effect or Possible Effect: The University is not in compliance with the Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: Below reporting threshold. Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for the Federal Pell Grant Program for the year ended May 31, 2025. Identification of Repeat Finding: This is a repeat of prior year finding 2024-003. Recommendation: We recommend that the University enhance its procedures over cash management to ensure timely elimination of excess cash balances. Views of Responsible Officials: Upon reviewing the situation that led to this error, it was a result of batches from the student accounts system not being posted to the accounting general ledger on a daily basis. To prevent this error from occurring in the future, the Director of Student Accounts will post batches daily going forward. Additionally, the Controller is cross trained on this function and will fill in when needed to post batches.