Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to ensure reasonable compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the effective date and enrollment status correctly or timely. In addition, the University did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Reported. Context: During our testing, we noted that the enrollment effective date of 6 of the 60 students tested was not reported correctly to NSLDS. We also noted that the change in enrollment status of 3 of the 60 students tested was not reported timely to NSLDS. We also noted the program enrollment effective date of 2 of the 60 students tested did not match the enrollment effective date. Additionally, we did not note evidence of a key control occurring for enrollment reporting. Cause: The University did not have proper controls or procedures in place to verify students' status in NSLDS matched the institution’s records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2024-002. Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status, and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the University was unable to provide documentation evidencing the performance of a key control over the timeliness and accuracy of Common Origination and Disbursement (COD) disbursements reporting. Questioned costs: None reported. Context: The University could not provide evidence that the key control review was performed for any of the 60 disbursements selected for testing. Cause: The University does not maintain documentation to evidence their review to ensure disbursements are reported to COD timely and accurately. Effect: The absence of documented review increases the risk that disbursement data reported to COD may be inaccurate or untimely, which could result in inaccurate student records and may contribute to improper or excess student aid awards. Repeat Finding: Yes, 2024-004. Recommendation: We recommend the University retain evidence that key controls over COD reporting were performed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During eligibility testing, we noted that the University did not provide documentation evidencing that a review of a professional judgment decision had been performed. Questioned costs: None reported. Context: Of the 40 student files selected for eligibility testing, one student had a professional judgment determination. While supporting documentation for the professional judgement decision was available, the University was unable to provide evidence that the decision had been reviewed. Cause: The University does not maintain documentation to demonstrate that professional judgment decisions are subject to an independent review in accordance with established procedures. Effect: The lack of documentation of review of professional judgment decisions increases the risk that such determinations may not be appropriately evaluated, which could result in student financial need not being accurately assessed and students being improperly awarded or underserved. Repeat Finding: Yes, 2024-003. Recommendation: We recommend the University enhance its procedures for reviewing professional judgement decisions to ensure that evidence of review is documented and retained. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Compliance, Other Matter Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (Pub. L. No. 106-102) and its implementing regulations require financial institutions to protect the security, confidentiality, and integrity of customer information (16 CFR Part 314). Title IV-eligible institutions participating in the Federal Student Financial Assistance Programs are considered financial institutions subject to GLBA requirements and agree to comply with these requirements through their Program Participation Agreement with the U.S. Department of Education. Institutions are required to safeguard student financial aid information, including implementing administrative, technical, and physical safeguards, and periodically evaluating the effectiveness of those safeguards, including user access controls (16 CFR 314.3 and 314.4). Condition: CLA identified that the University does not meet all the compliance requirements of the GLBA safeguards rule. Questioned costs: None reported. Context: During our testing, we noted that the University did not demonstrate compliance with certain requirements of the GLBA Safeguards Rule related to ongoing monitoring of system access. Cause: The University does not have a process in place to periodically review and evaluate user access controls. Effect: The absence of periodic review of user access controls increases the risk of unauthorized access to sensitive student financial aid information, which could compromise the security andconfidentiality of protected data. Repeat Finding: No. Recommendation: We recommend the University review the GLBA Safeguards Rule and implement appropriate processes and controls to ensure compliance with all applicable provisions. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 181701 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the University was unable to provide evidence that a key control to verify the accuracy and timeliness of payments to program participants had been performed. Questioned costs: None reported. Context: The University was unable to provide documentation evidencing that the key control was performed for any of the 40 disbursements selected for testing. Cause: The University’s procedures for reviewing payments to program participants did not include documentation to provide evidence that the review had occurred. Effect: The lack of documented review increases the risk that errors in payments to program participants may not be identified or corrected in a timely manner. Repeat Finding: No. Recommendation: We recommend the University implement procedures to ensure evidence of the key control review over payments to program participants is documented and retained. View of Responsible Official: There is no disagreement with the audit finding.