Audit 394674

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Through our testing of 40 students whose accounts had a credit balance resulting from federal funds during the year, we noted that ten students at Keene State College and seven students at University of New Hampshire did not have the credit balance refunded within the 14 day period. Context: The institution’s policies and procedures did not successfully track the 14 day period required for credit balance refunds. Cause: The policies and procedures of the institution did not ensure that refund compliance requirements were timely met. Questioned Costs: None Possible Asserted Effect: The institution did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: Yes – 2024-001 Auditor’s Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include accurate information. Condition: We noted, during our testing, that two students from Keene State College and two students from Plymouth State University out of 60 students tested whose enrollment status was not timely reported to NSLDS. In addition, one student’s status in NSLDS did not agree to the transcript at Plymouth State University and one student’s effective date in NSLDS did not agree to the institutional records at Plymouth State University. Context: The institution’s processes and controls did not ensure that student status changes were timely reported to NSLDS. Cause: The institution’s processes and controls did not ensure that student status changes were timely reported to NSLDS. Questioned Costs: None Possible Asserted Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes 2024-002 Auditor’s Recommendation: We recommend the institution review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s student aid index for that period. Condition: We noted one student from Keene State College was awarded need based aid over their calculated need. In addition, we noted, during our testing, that one student from Keene State College and one student from the University of New Hampshire whose subsidized loans were not maximized before originating an unsubsidized loan. Context: The institution’s processes and controls did not ensure that student was awarded appropriately based on the students need calculation. Cause: The institution’s processes and controls did not ensure the student was awarded need based aid up to their need calculation. Questioned Costs: None Possible Asserted Effect: Students are awarded aid beyond their need calculation. Repeat Finding: No Auditor’s Recommendation: We recommend the institution review its reporting procedures to ensure that awarding is within the need calculation. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 668.32(f), students must maintain satisfactory academic progress (SAP) in his or her course of study according to the institution’s published standards of satisfactory academic progress that meet the requirements of 34 CFR 668.34. Condition: Of the 60 students tested, we noted one student from the University of New Hampshire who was disbursed aid after failing SAP and was no longer eligible to receive federal student aid. In addition, we noted, two students from University of New Hampshire who failed SAP in Spring of 2025 and were not provided the proper notification that they had failed SAP and were no longer eligible to receive federal student aid. Context: The institution’s processes and controls did not ensure that students were properly notified they were no longer eligible and continued awarding aid to students no longer eligible. Cause: The institution’s processes and controls did not ensure the student’s failing SAP received the proper notification and eligibility terminated. Questioned Costs: None Possible Asserted Effect: Students are disbursed aid when they no longer are eligible. Repeat Finding: No Auditor’s Recommendation: We recommend the institution review its SAP policies to ensure they met the minimum requirements and that they are fully implemented. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: N/A; award year 2024-2025 Award Period: July 01, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: One of the students at the University of New Hampshire of the ten tested did not have the required support retained in the student files. Context: The University’s processes and controls did not ensure the verification process was completed before disbursements of awards. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Questioned Costs: None Possible Asserted Effect: The University did not either obtain or retain information to support the verification process. Documentation needs to be retained to show that the verification process was completed. Repeat Finding: No Auditor’s Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: There is no disagreement with the audit finding.