2025‐001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 34 CFR 685.203(d), the aggregate unpaid principal amount of all Direct Subsidized Loans and Subsidized Federal Stafford Loans made to a student but excluding the amount of capitalized interest may not exceed the following: (1) $23,000 in the case of any student who has not successfully completed a program of study at the undergraduate level; (2) $65,500 in the case of a graduate or professional student, including loans for undergraduate study. In accordance with 34 CFR 685.203(e), the total amount of Direct Unsubsidized Loans, Unsubsidized Federal Stafford Loans, and Federal SLS Loans, excluding the amount of capitalized interest, may not exceed the following: (1) For a dependent undergraduate student, $31,000 minus any Direct Subsidized Loan and Subsidized Federal Stafford Loan amounts, unless the student qualifies under paragraph (c) of this section for additional eligibility or qualified for that additional eligibility under the Federal SLS Program; (2) For an independent undergraduate or a dependent undergraduate who qualifies for additional eligibility under paragraph (c) of this section or qualified for this additional eligibility under the Federal SLS Program, $57,500 minus any Direct Subsidized Loan and Subsidized Federal Stafford Loan amounts; (3) For a graduate or professional student, $138,500, including any loans for undergraduate study, minus any Direct Subsidized Loan, Subsidized Federal Stafford Loan, and Federal SLS Program loan amounts. Statement of Condition: During the audit, it was noted that a student included in the testing sample was awarded direct loans beyond aggregate limits. The student’s aggregate loans exceeded the limit prior to awarding, so the entirety of the current year award was in excess. Questioned Costs: The detected monetary error in the award is $19,038. Rather than extrapolating the error, the University was able to identify all applicable students for which this error also exists. Across 16 graduate students, including the individual selected in the audit sample, $137,427 in direct loans were awarded to students whose lifetime aggregate limits were at or in excess of the limit prior to awarding for the 2024‐25 award year. Across 21 undergraduate students, $109,542 in direct loans were awarded to students whose undergraduate aggregate limits were at or in excess of the limit prior to awarding for the 2024‐25 award year. Across 4 undergraduate students, $5,245 in direct subsidized loans were awarded to students whose undergraduate subsidized limits were at or in excess of the limit prior to awarding for the 2024‐25 award year. The total monetary error identified is $252,214 over‐awarded to 41 students. Perspective Information: The audit included a detailed testing of files for 30 students, to which direct loan funds were disbursed. This significant deficiency applies to 1, indicating an error rate of 3.00%. Cause and Effect: This issue is caused by the absence of timely National Student Loan Data System (NSLDS) post‐screening updates for the 2024‐25 award year amidst reporting changes for colleges and universities. The release of this data was delayed to Spring 2025 and the Department recognized the ongoing administrative burden that this delay represents; to help support schools, NSLDS agreed to start providing an Excel file (.xlsx) that identifies applicants for the 2024–25 award year whose eligibility status has changed since their initial 2024–25 FAFSA submission. This excel file was not sufficiently referenced for the students who were over‐awarded direct loans related to codes 09 (student has exceeded subsidized aggregate loan limit) and 10 (student has exceeded combined aggregate loan limit), resulting in the noted over‐awards. Per discussion with University personnel, the post‐screening data updates are being received and are functional for new awards made in Spring 2025 and after. Recommendation: The University should ensure that all available data is reviewed, and that additional information is requested as needed to verify students are awarded within the limitations in place to ensure awards are made only in appropriate circumstances. Aggregate loan totals, along with other facets of data that would affect award eligibility, should be confirmed prior to awarding and disbursement. View of Responsible Officials: Corrective action is being implemented to include contacting each student to inform them of the required reaffirmation process and to ensure that, in the event postscreening data is provided outside the automated process, those files are reviewed and applied promptly.
2025‐002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education ‐ Federal Work Study Program, ALN #84.033) Criteria: In accordance with the 2024‐2025 Federal Student Aid Handbook, in general, students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work‐study experience. Any such exemptions must be documented. Statement of Condition: During the audit, it was noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of reasonable exemption. Questioned Costs: The known monetary error is an over‐payment of $23. Extrapolation of the error across all students and pay periods that may have been affected estimates total possible monetary error of $7,149. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 5 files for students participating in the Federal Work Study program during the 2024‐2025 award year, and limited detail testing of an additional 6 students’ Federal Work Study documents pertaining to this specific attribute. For the 11 students tested, auditors vouched class schedules, timecards, and paystubs for two specific pay periods, one in each semester. Of these students for the specific pay periods tested, overlap between submitted work study hours paid and classes scheduled without reasonable exception was identified in the records for 2 students. Therefore, we consider the error rate as 18.18%. Cause and Effect: In one case of conflicting times, the student’s professor could not verify whether there had been changes to their regularly scheduled class time to vouch for reasonable exemption for an allowable overlap in time; in the second case, the student manually entered their time for submission, mistakenly overlapping with the beginning of their scheduled class for multiple days during their first week employed. In both instances, supervisors did not identify the conflicts when reviewing and submitting timesheets for payroll processing and funds were paid to the students for the overlapping times, which is prohibited without an adequate exemption that has been appropriately documented. Recommendation: The University should ensure that proper safeguards, in both software and personnel, are in place to prevent, identify, and remediate such errors to prevent over‐payment of federal aid funds. View of Responsible Officials: Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Corrective action has been implemented to ensure such conflicts are prevented in the future.