Assistance Listing, Federal Agency, and Program Name ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding Yes 2024 001 Criteria Institutions are required to report enrollment information under the Pell Grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845 0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Condition The University of Rio Grande did not report student status changes accurately for certain students who withdrew during the year. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Of the 40 students tested for student status change, 2 student status changes were not properly reported. Cause and Effect The University did not have a process in place to ensure proper reporting for all student status changes. As a result, there were instances where reporting of a student who withdrew did not occur. Recommendation We recommend that the University put a control process in place to ensure all student status changes are reported timely and accurately. Views of Responsible Officials and Corrective Action Plan The Director of Financial Aid and the Registrar will establish a formal communication and notification process to review enrollment statuses and status changes for all students who begin attendance each semester. Recurring meetings and calendar reminders will be scheduled every 30 days to ensure this review is conducted consistently and collaboratively. The University is also in the process of updating its student withdrawal process from a paper/PDF form to a fully electronic submission process. This new system will automatically notify all pertinent departments when a student initiates a withdrawal, ensuring timely communication and reducing the likelihood of missed or delayed reporting. Implementing this electronic workflow will further strengthen internal controls and directly support the corrective action plan. The Director of Financial Aid will receive direct access to the National Student Clearinghouse and will be enrolled in automated email alerts to support timely and accurate reporting of all enrollment changes. In the event the Director of Financial Aid is unavailable for the scheduled 30-day review, a designated member of the Financial Aid Office will participate in the review to ensure the process is completed without interruption.
Assistance Listing, Federal Agency, and Program Name ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria The University has 45 days from the date the University determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds to the Department of Education. Withdrawal dates are defined as the time when the student officially withdrawals or expresses notification to withdrawal or, if the student does not officially withdraw, the date the University determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)). Condition The University did not return all Title IV funds in a timely manner to the Department of Education for certain students who withdrew during the year. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Of the 11 students tested, for 3 students, the University did not calculate the required return in a timely manner and did not return funds to the Department of Education within the required time frame. Cause and Effect The University did not have adequate controls to return funds to the Department of Education after the calculation had been performed in accordance with the regulations, which resulted in late returns. Recommendation We recommend implementing a control to ensure that all Title IV funds are returned within the required time frame. Views of Responsible Officials and Planned Corrective Actions The primary underlying cause of this issues was the significant lack of training, guidance, and onboarding support provided by Anthology during the implementation of the Anthology Student system. Prior to golive, the University was unable to fully test the Title IV awarding, disbursing, and adjustment processes because file transmissions to COD (Common Origination and Disbursement) can only be executed using live data. This limitation prevented staff from validating system behavior in a testing environment and further hindered the understanding of the required processes, procedures, and communication workflows between Anthology Student and COD. As a result, staff lacked critical knowledge needed to ensure Title IV transactions—including those tied to Return to Title IV (R2T4) calculations—were correctly generated and transmitted. Corrective action has already been implemented. The Financial Aid Office now manually reviews and verifies all Title IV awarding, disbursement, and adjustment transactions—including those related to R2T4—to ensure successful submission to COD. Once the R2T4 calculation has been completed in COD, the Financial Aid Advisor manually updates the student’s account in Anthology Student. The Business Office then posts the corresponding adjustment to the student ledger. After the Business Office posts the Title IV activity, the Financial Aid Advisor manually processes the related adjustments and disbursements through COD to ensure the timely return and/or disbursement of funds associated with the R2T4 calculation. These manual oversight procedures will remain in place until the University receives additional and adequate training from Anthology that ensures consistent and reliable electronic transmission between Anthology Student and COD.
Assistance Listing, Federal Agency, and Program Name ALNs 84.063 and 84.268; Department of Education; Federal Pell Grant Program and Federal Direct Loan Program Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria Institutions are required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. (34 CFR 690.83) Condition The University did not have controls in place to ensure appropriate reporting to COD. Questioned Costs None Identification of How Questioned Costs Were Computed None Context The Unviersity was not performing reconciliations between the student system and COD to ensure appropriate reporting to COD for Pell Grants and Direct Loans. Cause and Effect The College experienced a transition to a new student system. As a result, the control was not operating effectively to prepare and review reconciliations between the new transition to the student system and COD. Recommendation The College should implement procedures and controls to review the amount of Pell Grants and Direct Loans reported to COD to ensure it agrees to what has been disbursed to students. Views of Responsible Officials and Planned Corrective Actions The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to the challenges experienced with Return to Title IV (R2T4) processing, University staff did not receive adequate instruction on how to perform Title IV reconciliations within the system or how to extract the data needed to compare internal records with COD. This lack of foundational training made it extremely difficult for staff to understand required reconciliation procedures, identify discrepancies, or troubleshoot system-related issues. In addition, the technical limitations of Anthology Student significantly hindered the University’s ability to perform timely and accurate reconciliations. Anthology Student does not provide a comprehensive or efficient reporting tool that allows users to pull Title IV awarding and disbursement data in a format that aligns with COD records. Staff must manually compile information from multiple system screens and reports, a process that takes several hours and still does not produce a clean, fully reconcilable output. Discussions with other Anthology client institutions confirmed that they are experiencing similar challenges with timely reconciliations due to the system’s reporting limitations. Compounding these reporting challenges, the batch transmission functionality between Anthology Student and COD has been unreliable. Files routinely fail or become “stuck” during transmission, but Anthology offers limited visibility into batch processing status. Until February 2026, the University relied on a system report to identify failed or stalled batches; however, an Anthology system update removed this report and the capability altogether. Without access to this tool, staff have had little ability to monitor or verify successful COD transmission, further complicating reconciliation efforts. Another contributing factor is staffing capacity. The Financial Aid Office has limited personnel, and the extensive time required to manually pull data, consolidate reports, and investigate discrepancies has made it challenging to dedicate the uninterrupted hours required for reconciliation—especially without adequate system training or tools. The University is taking the following steps to address this finding: scheduled reconcilation intervals, staff training and support, and enhanced manual oversight. These actions will remain in place until Anthology Student provides reliable reporting capabilities and complete, consistent training, enabling the University to perform reconciliations accurately and on time.
Assistance Listing, Federal Agency, and Program Name ALNs 84.063; Department of Education; Federal Pell Grant Program Federal Award Identification Number and Year N/A Pass through Entity None Finding Type Significant deficiency Repeat Finding No Criteria Before disbursing Pell Grant funds, the institution must notify the student of the amount of Title IV funds including the Pell Grant the students are scheduled to receive and explain how and when those funds will be disbursed. Institutions must follow the general Title IV disbursement notice requirements under 34 CFR 668.165. Condition The University did not provide notifications to certain students related to Pell grants. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context There were 3 students in a sample of 40 students receiving Pell Grant funds which did not receive a notification. Cause and Effect A control was lacking to ensure the notifications were sent to all students receiving Pell Grant funds. Recommendation We recommend a control be implemented to ensure notifications are sent to all students receiving Pell Grant funds. Views of Responsible Officials and Planned Corrective Actions During the implementation of Anthology Student, the University did not receive sufficient system configuration support or training from Anthology to properly establish automated Financial Aid Offer and Title IV notification workflows. As a result, the institution did not have the required functionality in place to automatically notify students of their Pell Grant eligibility, scheduled disbursement amounts, and the timing of those disbursements as required under 34 CFR 668.165(a). This lack of configuration and training created gaps in communication and ultimately led to instances in which students did not receive timely notifications before Pell Grant funds were disbursed. Once the University identified these deficiencies, immediate corrective measures were implemented to ensure short-term compliance. Beginning in May 2025, the Financial Aid Office instituted a formal manual notification process. Staff now generate Packaging Status and Disbursement reports on a weekly basis, and these reports are reviewed and acted upon at least bi-weekly to ensure that all upcoming disbursements are captured. Individualized Title IV and Pell Grant notifications are sent to students prior to the crediting of funds. To strengthen internal controls, a secondary review was added so that another staff member verifies that all required notifications have been issued before any Title IV disbursement occurs. These interim procedures and safeguards will remain in effect until the automated notification workflow is fully configured, tested, and implemented.