Audit 371919

Special Tests and Provisions – Return of Title IV U.S. Department of Education, Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program, Assistance Listing Number 84.007 Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.033 Federal Work-Study Program, Assistance Listing 84.379 Teacher Education Assistance for College and Higher Education Grants Program Year 2024–2025 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Per 34 CFR §668.22, institutions are required to determine the amount of Title IV funds that must be returned when a student withdraws from the institution before completing the payment period or period of enrollment. The calculation must be performed accurately and timely using the prescribed formula to ensure compliance with federal regulations. Condition: The University's processes did not ensure the calculations performed to calculate required return of funds were accurate. Questioned Costs: $0 Context: Out of the population of 35 students with withdraw status subject to potential returned funds, a sample of four students were selected for testing. For two of the four samples tested, the University incorrectly calculated the amount of Title IV funds to be returned. Effect: The University returned an incorrect amount of Title IV funds to the Department of Education for the affected students, potentially resulting in noncompliance with federal regulations and financial liability. Cause: The errors appear to be the result of manual data entry and insufficient review controls within the financial aid office’s Return of Title IV funds process. Recommendation: We recommend the University strengthen its internal controls over the Return of Title IV funds calculation process. This should include implementing a secondary review of all calculations and ensuring accurate documentation of withdrawal dates and payment period parameters. Views of Responsible Officials: Management concurs with the finding and recommendation. Further information on the corrective action plan will be provided by management.

Special Tests and Provisions – Enrollment Reporting U.S. Department of Education, Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program Program Year 2024–2025 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Per 2 CFR §200.303, 34 CFR 685.309, OMB No. 1845-0035 and the Federal Student Aid Handbook, institutions are required to report accurate and timely enrollment status changes, including graduation, to the NSLDS via the National Student Clearinghouse or other reporting mechanisms. Accurate reporting ensures proper administration of Title IV funds and prevents inappropriate loan deferments or repayments. Condition: The University did not ensure that all graduation data was accurately transmitted and reflected in the National Student Loan Data System (NSLDS). Questioned Costs: $0 Context: Out of the population of 167 students subject to enrollment reporting, a sample of 17 students were selected for testing. For 1 of the 17 students tested, NSLDS did not reflect the student’s graduation status on campus or program students in which the University’s records reported graduated. Effect: Failure to report accurate enrollment status may result in incorrect deferment or repayment statuses for student borrowers, potentially impacting loan servicing and compliance with federal regulations. Cause: The errors appear to be the result of a lapse in control by the University to ensure all graduation data was accurately transmitted and reflected in the NSLDS. Recommendation: We recommend the University enhance its controls over the enrollment reporting process to ensure that all graduation data is accurately and timely reported to the NSLDS. This may include periodic reconciliations between internal records and NSLDS data and follow-up procedures for discrepancies. Views of Responsible Officials: Management concurs with the finding and recommendation. Further information on the corrective action plan will be provided by management.