Audit 372939

Student Financial Assistance Cluster 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 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the amounts to be returned to the U.S. Department of Education were correct and notification of a post-withdrawal disbursement could not be located. Questioned costs - $0 Context – Out of the population of 122 students who withdrew, 23 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The R2T4 calculations for 6 students in the sample were correct, but the amount returned to COD was based on the net loan amount rather than the gross amount. The University returned more funds to the COD than was required. Additionally, one student was eligible for a post-withdrawal disbursement, but documentation that the student had been notified was not able to be obtained. Effect – The amount originally returned was incorrect. Cause – The University’s internal controls did not ensure proper inputting of information to return funds. Identification as a repeat finding, if applicable – 2024-001 and 2023-001 Recommendation – The University should update their controls to ensure the R2T4 inputs for the return of funds are correct. Views of responsible officials and planned corrective actions – The University concurs that errors occurred in posting the loan amount to be returned for six (6) Return of Title IV (R2T4) transactions identified during the audit review resulting in a total return of funds for the six (6) students which was $757.56 more than required. Specifically, the actual calculations were completed accurately, but each student’s loan amount was adjusted for loan origination fees when they should not have been adjusted. All updates to records were made for those that required updating. The University also acknowledges that documentation for one student that was required for a post-withdrawal disbursement notification cannot be located. Although the calculation and determination were completed, the supporting documentation of that notification was not properly retained in the student’s record.

Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University did not report two student’s enrollment changes. The University did not timely report status changes for 20 students. Effect – The University reported incorrect statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Additionally, an incorrect configuration within the University’s student system to cause errors in how enrollment status changes were reported, which resulted in the National Student Clearinghouse placing a temporary hold on all new submissions until the discrepancy was resolved. Identification as repeat finding, if applicable – 2024-002 and 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The University concurs that errors occurred which resulted in the instances of untimely and/or inaccurate student status reporting to the National Student Loan Data System (“NSLDS”) identified during the audit review. Specifically, one parameter setting within the University’s student information system (“SIS”) had been inadvertently configured to populate a data field with information that did not correspond to the enrollment reporting fields accurately in National Student Clearinghouse (“NSC”) or NSLDS. The Registrar’s Office initiated a contemporaneous review of the internal systems working with the University’s service providers to determine the cause of the inaccurate data populating during the enrollment reporting process in award year 2024-2025. That review found that human error contributed to the inaccurate configuration and inaccurate and/or untimely reporting. This appeared to be due in part to a misinterpretation by staff of certain data field(s) in the University’s SIS and the reporting mechanisms between NSC and NSLDS, causing inaccurate and/or untimely enrollment reporting. As part of its response to this audit review, the University continues the review and investigation of its internal systems, service providers, and staff to ensure the root causes of any enrollment reporting deficiencies have been remedied. The University will include, as part of the supplemental Corrective Action Plan, details of that review, plans for analysis and remedial actions currently underway, as well as those corrective measures the University plans to take going forward.