Audit 388064

Finding 2025-001 - Significant Deficiency, Compliance Federal Assistance Listing Number: 84.268 U.S. Department Of Education Student Financial Aid Cluster - Eligibility Criteria: According to the 2024-2025 Federal Student Aid Handbook, Volume 3, Chapter 3, Direct Subsidized Loans may only be awarded to the extent that a student has unmet financial need, calculated as Cost of Attendance (COA) minus Student Aid Index (SAI) and Other Financial Assistance (OFA). Institutions must ensure that need-based aid does not exceed financial need, and that subsidized loan eligibility is exhausted before awarding Direct Unsubsidized loans. Condition: In our nonstatistical sample of 40 students selected for testing for eligibility in the year ended June 30, 2025, we identified two instances where the University awarded Direct Subsidized Loans in excess of the students’ demonstrated financial need. In both cases, this resulted in a corresponding underaward of Direct Unsubsidized Loan funds. Context: These two exceptions were identified from a sample of 40 students tested for compliance with Direct Loan eligibility requirements. The errors occurred due to incorrect application of financial need calculations at the time of loan packaging or as a result of failure to adjust the loan awards when additional OFA was received. In total, the misallocation amounted to $9,500 between Direct Subsidized and Unsubsidized Loans. Effect: As a result of the misallocation of the loan awards between Direct Subsidized Loans and Direct Unsubsidized Loans, the Department of Education may not receive as much in interest costs as should have been allocated to the students’ loans while in school. Questioned Costs: There were no direct questioned costs as a result of this finding. The interest charged to the student would be approximately $620 less per each year the student remains in school at the 6.53% interest rate for undergraduate Direct Subsidized and Unsubsidized Loans. Cause: The errors resulted from manual loan packaging procedures and insufficient review controls to verify that subsidized loan amounts did not exceed financial need before disbursement or after changes to the students’ OFA that occurred during the period of enrollment. Identification Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the University implement strengthened internal controls over the Direct Loan packaging process, including system edits or secondary reviews to prevent the overaward of subsidized loans. We recognize that the University has discontinued operations after the Summer 2025 semester and the implementation of the recommendations would not be considered necessary given the closure of the University. Views Of Responsible Officials (Unaudited): We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” We have not adjusted the student’s loan awards given the identification of the overaward took place after the end of the loan period for each student. As the University has closed after August 15, 2025, no additional actions are considered necessary. Completion Date: August 2025 Contact Person: Ann Spall, Chief Financial Officer