Return of Title IV (R2T4) Calculations Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not return all required federal funds timely when a student withdrew or stopped attending. Additionally, the University did not make the post-withdrawal disbursements timely.
Criteria: 34 CFR 668.22
Questioned Costs: $2,069
Context: Out of 30 students tested, 3 students who withdrew during the audit period had funds returned late ranging from 14 to 252 days late but within the audit period, and 2 students had post-withdrawal disbursements made more than 180 days after the eligible date. One additional student was eligible for a post-withdrawal disbursement which had not been made during the fiscal year, and at the time of the report, was past the number of days allowed for a disbursement. Five students out of the 6 listed were before the spring 2023 semester. The return that was 14 days late was in the spring 2023 semester. All students that could be corrected during the audit process were corrected.
Cause: There has been significant turnover in the financial aid department at the University during the period under audit.
Effect: Federal funding was not returned timely. The post withdrawal disbursements made late were Pell disbursements totaling $1,536.
Identification as repeat finding, if applicable: Yes, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend that the University continue to provide additional training for counselors performing R2T4 calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not return all required federal funds timely when a student withdrew or stopped attending. Additionally, the University did not make the post-withdrawal disbursements timely.
Criteria: 34 CFR 668.22
Questioned Costs: $2,069
Context: Out of 30 students tested, 3 students who withdrew during the audit period had funds returned late ranging from 14 to 252 days late but within the audit period, and 2 students had post-withdrawal disbursements made more than 180 days after the eligible date. One additional student was eligible for a post-withdrawal disbursement which had not been made during the fiscal year, and at the time of the report, was past the number of days allowed for a disbursement. Five students out of the 6 listed were before the spring 2023 semester. The return that was 14 days late was in the spring 2023 semester. All students that could be corrected during the audit process were corrected.
Cause: There has been significant turnover in the financial aid department at the University during the period under audit.
Effect: Federal funding was not returned timely. The post withdrawal disbursements made late were Pell disbursements totaling $1,536.
Identification as repeat finding, if applicable: Yes, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend that the University continue to provide additional training for counselors performing R2T4 calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 84 students tested, there were 12 students who withdrew whose enrollment status did not reflect that they had withdrawn in a timely manner. The students have not been corrected yet.
Cause: The system tracks the data needed for enrollment reporting, and this data was submitted to National Student Clearinghouse (NSC). The transfer of data from NSC to NSLDS did not reflect these students as withdrawn.
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, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with NSC to determine why the dates transferred to NSLDS did not reflect the withdrawal dates. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 84 students tested, there were 12 students who withdrew whose enrollment status did not reflect that they had withdrawn in a timely manner. The students have not been corrected yet.
Cause: The system tracks the data needed for enrollment reporting, and this data was submitted to National Student Clearinghouse (NSC). The transfer of data from NSC to NSLDS did not reflect these students as withdrawn.
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, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with NSC to determine why the dates transferred to NSLDS did not reflect the withdrawal dates. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: 4 students out of 60 were not properly awarded Pell based on enrollment status.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $2,280
Context: Two students were inadvertently awarded and paid Pell for more classes than they attended, resulting is $2,280 overawards. This was not corrected during the audit. One student was not paid Pell for all classes attended, resulting in an underaward of $381. One student was paid the fall 2022 Pell award but was not paid for spring and summer. This student was corrected during the audit process.
Cause: There was not an internal report run to verify that all changes in attendance resulted in the students being paid Pell for the classes in which they began attendance.
Effect: Pell was not awarded correctly based on enrollment status, resulting in overawards to some students and underawards to other students.
Identification as repeat finding, if applicable: Yes, 2022-005.
Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis and Loan Proration DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Students were not appropriately awarded subsidized loans based on need. Where there was a change in the student's cost of attendance or other aid, a recalculation of need based aid was not performed to catch adjustments before a second disbursement of aid was made. One student who was in the final semester to graduate did not have loan appropriately prorated. Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need based federal financial aid.
Criteria: 34 CFR 685.203
Questioned Costs: $394
Context: Out of 60 students, one student was not awarded aid appropriately based on need analysis. The student had eligibility for subsidized loans but was not awarded up to need, totaling $438. This student was corrected during the audit. One student’s proration was done in aggregate for loans instead of individually between subsidized loans and unsubsidized loans, resulting in an overaward of subsidized loans by $394. This student was not corrected during the audit process.
Cause: Additional scholarships were added after federal aid awarded but before the second disbursement was made. The validation check before the second disbursement was made did not catch these. The proration calculation was performed based on the total of $7,500 instead of $5,500.
Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay.
Identification as repeat finding, if applicable: Yes, 2022-004 and 2021-008.
Recommendation: We recommend the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. We also recommend that the student information system have notifications when a student's cost of attendance is adjusted to review need analysis and update awarding as needed. For loan proration, we recommend the University prorate remaining loans individually between subsidized and unsubsidized programs.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not return all required federal funds timely when a student withdrew or stopped attending. Additionally, the University did not make the post-withdrawal disbursements timely.
Criteria: 34 CFR 668.22
Questioned Costs: $2,069
Context: Out of 30 students tested, 3 students who withdrew during the audit period had funds returned late ranging from 14 to 252 days late but within the audit period, and 2 students had post-withdrawal disbursements made more than 180 days after the eligible date. One additional student was eligible for a post-withdrawal disbursement which had not been made during the fiscal year, and at the time of the report, was past the number of days allowed for a disbursement. Five students out of the 6 listed were before the spring 2023 semester. The return that was 14 days late was in the spring 2023 semester. All students that could be corrected during the audit process were corrected.
Cause: There has been significant turnover in the financial aid department at the University during the period under audit.
Effect: Federal funding was not returned timely. The post withdrawal disbursements made late were Pell disbursements totaling $1,536.
Identification as repeat finding, if applicable: Yes, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend that the University continue to provide additional training for counselors performing R2T4 calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not return all required federal funds timely when a student withdrew or stopped attending. Additionally, the University did not make the post-withdrawal disbursements timely.
Criteria: 34 CFR 668.22
Questioned Costs: $2,069
Context: Out of 30 students tested, 3 students who withdrew during the audit period had funds returned late ranging from 14 to 252 days late but within the audit period, and 2 students had post-withdrawal disbursements made more than 180 days after the eligible date. One additional student was eligible for a post-withdrawal disbursement which had not been made during the fiscal year, and at the time of the report, was past the number of days allowed for a disbursement. Five students out of the 6 listed were before the spring 2023 semester. The return that was 14 days late was in the spring 2023 semester. All students that could be corrected during the audit process were corrected.
Cause: There has been significant turnover in the financial aid department at the University during the period under audit.
Effect: Federal funding was not returned timely. The post withdrawal disbursements made late were Pell disbursements totaling $1,536.
Identification as repeat finding, if applicable: Yes, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend that the University continue to provide additional training for counselors performing R2T4 calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 84 students tested, there were 12 students who withdrew whose enrollment status did not reflect that they had withdrawn in a timely manner. The students have not been corrected yet.
Cause: The system tracks the data needed for enrollment reporting, and this data was submitted to National Student Clearinghouse (NSC). The transfer of data from NSC to NSLDS did not reflect these students as withdrawn.
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, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with NSC to determine why the dates transferred to NSLDS did not reflect the withdrawal dates. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 84 students tested, there were 12 students who withdrew whose enrollment status did not reflect that they had withdrawn in a timely manner. The students have not been corrected yet.
Cause: The system tracks the data needed for enrollment reporting, and this data was submitted to National Student Clearinghouse (NSC). The transfer of data from NSC to NSLDS did not reflect these students as withdrawn.
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, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with NSC to determine why the dates transferred to NSLDS did not reflect the withdrawal dates. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board.
Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: 4 students out of 60 were not properly awarded Pell based on enrollment status.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $2,280
Context: Two students were inadvertently awarded and paid Pell for more classes than they attended, resulting is $2,280 overawards. This was not corrected during the audit. One student was not paid Pell for all classes attended, resulting in an underaward of $381. One student was paid the fall 2022 Pell award but was not paid for spring and summer. This student was corrected during the audit process.
Cause: There was not an internal report run to verify that all changes in attendance resulted in the students being paid Pell for the classes in which they began attendance.
Effect: Pell was not awarded correctly based on enrollment status, resulting in overawards to some students and underawards to other students.
Identification as repeat finding, if applicable: Yes, 2022-005.
Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis and Loan Proration DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Students were not appropriately awarded subsidized loans based on need. Where there was a change in the student's cost of attendance or other aid, a recalculation of need based aid was not performed to catch adjustments before a second disbursement of aid was made. One student who was in the final semester to graduate did not have loan appropriately prorated. Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need based federal financial aid.
Criteria: 34 CFR 685.203
Questioned Costs: $394
Context: Out of 60 students, one student was not awarded aid appropriately based on need analysis. The student had eligibility for subsidized loans but was not awarded up to need, totaling $438. This student was corrected during the audit. One student’s proration was done in aggregate for loans instead of individually between subsidized loans and unsubsidized loans, resulting in an overaward of subsidized loans by $394. This student was not corrected during the audit process.
Cause: Additional scholarships were added after federal aid awarded but before the second disbursement was made. The validation check before the second disbursement was made did not catch these. The proration calculation was performed based on the total of $7,500 instead of $5,500.
Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay.
Identification as repeat finding, if applicable: Yes, 2022-004 and 2021-008.
Recommendation: We recommend the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. We also recommend that the student information system have notifications when a student's cost of attendance is adjusted to review need analysis and update awarding as needed. For loan proration, we recommend the University prorate remaining loans individually between subsidized and unsubsidized programs.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.