Enrollment Reporting to NSLDS Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 57 students tested, 7 students had incorrect enrollment status reported, of which one student was an official withdrawal.
Cause: The University’s process has been manual to update all NSLDS reporting by student.
Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: Yes, 2022-002.
Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: There were 7 incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups.
Criteria: 34 CFR 668.22
Questioned Costs: $-0-
Context: Out of 10 students, 7 students who withdrew during the audit period tested had incorrect funds returned due to incorrect calendar setups resulting in $254 of Pell and $185 of Federal Direct Loans returned more than required. Because of the error rate but immaterial dollar amounts, this is classified as a significant deficiency.
Cause: The University uses a third party administrator to assist in processing R2T4’s. The third party administrator had incorrect calendar setups which resulted in all students completing less than 60% of the semester having an incorrect return.
Effect: Incorrect amount of unearned Title IV funds returned.
Identification as repeat finding, if applicable: Yes, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar setups and ensure the proper number of days are used in the calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: There were 7 incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups.
Criteria: 34 CFR 668.22
Questioned Costs: $-0-
Context: Out of 10 students, 7 students who withdrew during the audit period tested had incorrect funds returned due to incorrect calendar setups resulting in $254 of Pell and $185 of Federal Direct Loans returned more than required. Because of the error rate but immaterial dollar amounts, this is classified as a significant deficiency.
Cause: The University uses a third party administrator to assist in processing R2T4’s. The third party administrator had incorrect calendar setups which resulted in all students completing less than 60% of the semester having an incorrect return.
Effect: Incorrect amount of unearned Title IV funds returned.
Identification as repeat finding, if applicable: Yes, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar setups and ensure the proper number of days are used in the calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Documentation of Exit Counseling DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not retain evidence or providing exit counseling to all students who left or did not send exit counseling instructions timely.
Criteria: 34 CFR 685.304(b)
Questioned Costs: $-0-
Context: Out of 51 students tested for exit counseling, 2 students did not have any documentation of exit counseling being sent. These students were sent exit counseling notifications during the audit process.
Cause: With transitions in financial aid counselors, documentation of notifying students was not available.
Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The official cohort default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Right to Cancel Notifications DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Students were not consistently notified of their ability to cancel loan disbursements.
Criteria: 34 CFR 668.165(a)
Questioned Costs: $-0-
Context: The templates used to notify students of upcoming loan disbursements did not include the instructions on how to cancel the loan.
Cause: There was transition in the financial aid department and the templates used did not include the required language.
Effect: There was noncompliance with the right to cancel notifications.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University update the template used for right to cancel notifications to include all required language.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 57 students tested, 7 students had incorrect enrollment status reported, of which one student was an official withdrawal.
Cause: The University’s process has been manual to update all NSLDS reporting by student.
Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: Yes, 2022-002.
Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: There were 7 incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups.
Criteria: 34 CFR 668.22
Questioned Costs: $-0-
Context: Out of 10 students, 7 students who withdrew during the audit period tested had incorrect funds returned due to incorrect calendar setups resulting in $254 of Pell and $185 of Federal Direct Loans returned more than required. Because of the error rate but immaterial dollar amounts, this is classified as a significant deficiency.
Cause: The University uses a third party administrator to assist in processing R2T4’s. The third party administrator had incorrect calendar setups which resulted in all students completing less than 60% of the semester having an incorrect return.
Effect: Incorrect amount of unearned Title IV funds returned.
Identification as repeat finding, if applicable: Yes, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar setups and ensure the proper number of days are used in the calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: There were 7 incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups.
Criteria: 34 CFR 668.22
Questioned Costs: $-0-
Context: Out of 10 students, 7 students who withdrew during the audit period tested had incorrect funds returned due to incorrect calendar setups resulting in $254 of Pell and $185 of Federal Direct Loans returned more than required. Because of the error rate but immaterial dollar amounts, this is classified as a significant deficiency.
Cause: The University uses a third party administrator to assist in processing R2T4’s. The third party administrator had incorrect calendar setups which resulted in all students completing less than 60% of the semester having an incorrect return.
Effect: Incorrect amount of unearned Title IV funds returned.
Identification as repeat finding, if applicable: Yes, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005.
Recommendation: We recommend the University review the calendar setups and ensure the proper number of days are used in the calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Lack of Documentation of Exit Counseling DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not retain evidence or providing exit counseling to all students who left or did not send exit counseling instructions timely.
Criteria: 34 CFR 685.304(b)
Questioned Costs: $-0-
Context: Out of 51 students tested for exit counseling, 2 students did not have any documentation of exit counseling being sent. These students were sent exit counseling notifications during the audit process.
Cause: With transitions in financial aid counselors, documentation of notifying students was not available.
Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The official cohort default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Right to Cancel Notifications DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Students were not consistently notified of their ability to cancel loan disbursements.
Criteria: 34 CFR 668.165(a)
Questioned Costs: $-0-
Context: The templates used to notify students of upcoming loan disbursements did not include the instructions on how to cancel the loan.
Cause: There was transition in the financial aid department and the templates used did not include the required language.
Effect: There was noncompliance with the right to cancel notifications.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University update the template used for right to cancel notifications to include all required language.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.