Audit 393570

Federal Program Information: Direct Student Loans Program (ALN 84.268) Criteria or Specific Requirement: C. Cash Management: Federal regulations (34 CFR 668.166 (a)(1) & (b)) require that an institution disburse funds requested and received through the G5 system no later than three business days following receipt of those funds from ED. For institutions on the Advance Payment Method, any amount of Title IV funds not disbursed to recipients by the end of the third business day is considered excess cash. ED allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold. Condition: The University had six draws of Federal Funds that were held in excess of the allowable timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with cash management requirements. Questioned Costs: None. Context: The University had six instances of draws made during the current year that were held in excess of the allowable timeframe. Identification as a Repeat Finding: There was one similar finding identified in the prior year. See finding 2024-002. Recommendation: We recommend the University enhance its procedures and internal control over cash management to ensure that Federal Funds are not held in excess of allowable time frames. Views of Responsible Officials: Financial Aid and the Controller's Office continue to implement a bi-weekly reconciliation process to ensure that any excess funds are disbursed or returned via G5 within the 10-day window. The Controller’s Office has updated reporting practices that ensure that return of funds are appropriately notated as return of Title IV funds.

Federal Program Information: Pell Grant Program (ALN 84.063) Criteria or Specific Requirement: E. Eligibility: Federal regulations (34 CFR 690.80 (b)(1) & (b)(2)(i)(ii)) require that if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. If the student’s projected enrollment status changes during a payment period after the student has begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students. If a student's projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment status to reflect only those classes for which the student actually began attendance. Condition: For two of the students selected for testing, the University did not properly reassess the student’s enrollment status and as a result, over awarded Federal Pell Grant funds. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with Pell eligibility requirements, resulting in an over award. Questioned Costs: Known questioned costs are $1,848 and projected questioned costs to the entire population are $91,787. Context: 2 out of 18 students selected for testing. Identification as a Repeat Finding: There were no similar findings identified in the prior year. Recommendation: We recommend the University enhance its procedures over Pell eligibility requirements to ensure students are not over awarded. Views of Responsible Officials: Financial Aid will use a daily credit change report generated automatically from academic records to make any manual credit updates in the PowerFAIDS financial system. Additionally, Financial Aid will use selection sets within PowerFAIDS to identify any credit hour mismatches between what is manually reported versus what is integrated from Power Campus, the academic records database.

Federal Program Information: Direct Student Loans Program (ALN 84.268) Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Key items to test on origination records for the fiscal year are: award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: For two of the students selected for origination testing, we identified variances in the Cost of Attendance ("COA") reported to the COD system compared to the COA recorded in the University's system used for awarding Title IV aid to the student. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with key origination reporting requirements. No instances of over awards were noted. Questioned Costs: None. Context: 2 out of 40 students selected for testing appeared to have incorrect reported COA. Identification as a Repeat Finding: There were no similar findings identified in the prior year. Recommendation: We recommend the University enhance its procedures over COD origination reporting requirements to ensure students are not over awarded. Views of Responsible Officials: Financial Aid will originate direct loans at least one week prior to the scheduled disbursement date. For large origination files at semester starts, financial aid administrators will run simulation originations to work through origination and/or disbursement rejections prior to sending real originations at least one month prior to semester starts.

Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. At a minimum, institutions are required to certify enrollment every 60 days or every other month. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: Program Level: Significant data elements were inaccurately reported for certain students. Campus Level: Significant data elements were inaccurately reported for certain students and were not submitted within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 12 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS. For 2 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS and enrollment was not certified within the required timeframe. Identification as a Repeat Finding: There was one similar finding identified in the prior year. See finding 2024-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Financial Aid has generated a report specifically for the Registrar’s Office that indicates enrollment plans for students who stop attending or withdraw from all courses for a single semester. The Registrar’s Office will be using this report for reporting enrollment status changes for students via NSLDS.