Finding 2025-001 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.007, 84.033, 84.063, 84.379 and 84.268 Criteria: 34 CFR 668.164(e) requires a school to provide an up-to-date URL for Tier One Arrangement contracts and cost information for students related to those contracts for publication in a centralized database accessible to the public. Condition: The University did not disclose the URL for its cash management contract with Bank Mobile (a Tier One Arrangement) to the Department of Education timely as the contract had been in place since 2013 and the communication of the URL was not sent to the Department of Education until July 2025. Cause: The University did not have adequate internal controls to ensure ongoing monitoring of federal disclosure requirements related to Tier One arrangements. Specifically, responsibility for submitting and updating the required URL in the Department of Education’s centralized database was not clearly assigned, and no periodic compliance review process was in place to detect the missing disclosure. Effect: Failure to timely disclose the URL for the University’s Tier One Arrangement resulted in noncompliance with 34 CFR 668.164(e). The lack of timely reporting increases the risk that required information is not readily available to the public or to the Department of Education. Questioned Cost: None. Context: During review of the University’s compliance with Tier One Arrangement requirements, it was noted that the University had entered into a contract with BankMobile dating back to 2013 that met the requirements of a Tier One Arrangement when the Department of Education’s Cash Management Final Regulations were published in 2015. The disclosure requirements were effective beginning in the year ended June 30, 2017; however, we identified that the University’s contract was not listed on the Department of Education’s cash management contract listing during our audit for the year ended June 30, 2025. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommended to management that the University provide the required updates to the Department of Education and that the University monitor the Department of Education’s cash management contract listing periodically to ensure that the Department of Education updates its listing with the correct URLs for the contract and required disclosure information. Views Of Responsible Officials: Management has made the appropriate updates and communicated the URLs for its contract and cost information to the Department of Education in July 2025 for its contract with BankMobile. Management will monitor the Department of Education’s cash management contract listing and will ensure that the contract is listed once the Department of Education updates its cash management contracts database as the most recent update to the cash management contracts database published by the Department of Education listed an update date of mid-January 2024. Completion Date: July 2025 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Finding 2025-002 – Significant Deficiency: Eligibility - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.268 Criteria: Under the Federal Direct Loan program, institutions must determine student loan eligibility based on Cost of Attendance (COA), Student Aid Index (SAI), Other Financial Assistance (OFA), and remaining annual and aggregate loan limits. Schools are required to monitor annual loan limits based on the student’s academic grade level progression. Schools must ensure that loan awards reflect the grade level, COA, and OFA at the time of origination and must update loan eligibility when these factors change. Condition: In our nonstatistical sample of 40 students selected for eligibility testing, we noted 8 students were underawarded subsidized and/or unsubsidized loans and 1 student that was overawarded unsubsidized loans. Cause: The University did not have adequate controls in place to ensure that student loan eligibility was recalculated when key factors, such as academic grade level progression, COA adjustments, or changes in OFA, occurred after initial packaging. No additional secondary verification of loan eligibility following academic grade level progression or COA/OFA changes was completed. Effect: Eight students received underawards totaling $11,668, consisting of subsidized and unsubsidized Direct Loans for which they were eligible but did not receive. One student received an overaward of unsubsidized loans totaling $3,931. Failure to update loan eligibility increases the risk of noncompliance with federal regulations governing Direct Loan awards. Questioned Costs: $3,931 related to overaward of unsubsidized loans. The overaward is considered isolated and therefore no likely questioned costs were identified related to this overaward. The underawards are not considered to be questioned costs as no funds were expended related to the underawards. Context: During our audit, we identified 5 students in our sample that achieved an additional academic grade level progression after completion of attendance in the Spring 2024 semester. The students were packaged loans for the 2024-2025 academic year before the Spring 2024 semester ended without the academic grade level progression as impacted by completing the Spring 2024 semester factored into the student’s loan package. After the completion of the Spring 2024 semester, the students’ loans were not updated to provide the student with additional aid available to them such as when a student progress from a 2nd year to a 3rd year student. The remaining 3 students that had underawards of subsidized and unsubsidized direct loans were due to the students not being repackaged aid after the student’s Cost of Attendance (COA) or Other Financial Assistance (OFA) was adjusted. The overaward identified for one student of $3,931 was due to the COA not being adjusted for a reduction in expected enrollment for the Spring 2025 and Summer 2025 semesters. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that the University strengthen internal controls over loan packaging and eligibility determinations by implementing systematic controls within the financial aid system to ensure that academic grade level progression, COA revisions, and OFA changes automatically prompt a required review of loan eligibility and by establishing a post-term audit process to confirm that students who progress to a new grade level or whose budgets change have been appropriately repackaged. Views Of Responsible Officials: Management concurs with the finding. The University has implemented controls to ensure that academic grade level progression and COA/OFA adjustments trigger a mandatory review of eligibility through the use of new reports and workflows. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Finding 2025-003 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.268, 84.007, 84.063, 84.379 Criteria: Under federal Return to Title IV (R2T4) requirements, an institution must determine the earned and unearned portions of the Title IV aid based on the amount of time a student was scheduled to be in attendance as of the date the student ceased attendance. For students enrolled in modular programs, the R2T4 calculation must use the number of days between the start of the first module and the originally scheduled end date of the last module the student was expected to attend, when determining the scheduled days in the period when the student receives direct loans and no R2T4 Freeze date is utilized by the institution. Condition: In our nonstatistical sample of 20 students tested for R2T4 compliance requirements, we noted 5 students who were enrolled in modular programs, who were awarded and received Federal Direct Loans, and had scheduled enrollment in both the 1st 8-week session and 2nd 8-week session of a semester in the year ended June 30, 2025 where the University improperly used the end date of the 1st 8-week session as the scheduled end date in the R2T4 calculation as opposed to using the end date of the 2nd 8-week session as the scheduled end date in the R2T4 calculation. Cause: The University did not have adequate controls to ensure that the R2T4 calculations for students enrolled in modular programs incorporated the correct scheduled end date for all modules the student was expected to attend. Effect: As a result of using the improper scheduled end date, the University’s calculation of the amount of aid earned by the students exceeded the amount of aid earned that we recalculated by $6,308. This resulted in the University and the students being able to keep $6,308 of a combination of Pell grant, direct subsidized loans, and direct unsubsidized loans that should have been returned to the U.S. Department of Education. Questioned Costs: We identified questioned costs in our sample of $6,308. The amount of estimated likely questioned costs based on an extrapolating the error identified to the remaining population of withdrawals that took place in a 1st 8-week session totaled $35,384. Context: We noted the error identified for 1 student in the Fall 2024 semester and for 4 students in the Spring 2025 semester. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend the University strengthen internal controls over R2T4 calculations for modular programs by revising R2T4 procedures to require verification of all modules the student was scheduled to attend at the time of withdrawal, implementing system prompts or checklists to ensure staff used the scheduled end date of the last module the student was expected to attend when determining the number of scheduled days in the R2T4 calculation, and performing periodic quality-control reviews of R2T4 files involving modular enrollment to ensure accurate determination of scheduled days. We recommend that the University perform recalculations of its modular returns for students who withdrew from a 1st 8-week session and were originally enrolled in both a 1st 8-week session and 2nd 8-week session in the year ended June 30, 2025, update its scheduled end dates utilized the R2T4 calculations, and return any additional unearned funds based on the revised calculations. Views Of Responsible Officials: Management concurs with the finding. The University is updating its written R2T4 procedures to ensure the appropriate scheduled end date is consistently used for students enrolled in modular programs. System enhancements and new workflow controls will be implemented to require documentation of all modules a student was scheduled to attend. The University will work to recalculate returns for students who withdrew from modules as recommended. Anticipated Completion Date: March 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Finding 2025-004 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.268, 84.007, 84.063, 84.379 Criteria: Under federal Return to Title IV (R2T4) requirements, an institution must return any aid required to be returned to the Department of Education within 45 days of the date of the institution’s determination that a student withdrew from the institution. Condition: In our nonstatistical sample of 20 students tested for R2T4 compliance requirements, we noted one student whose Title IV return was not completed within the 45-day required timeframe. Cause: The University did not have sufficient internal controls to ensure timely processing of Return to Title IV (R2T4) funds. Specifically, existing procedures did not include adequate monitoring to verify that all unearned Title IV funds were returned within the 45-day timeframe following the University’s determination of withdrawal. Effect: Failure to return unearned Title IV funds within the required timeframe results in noncompliance with R2T4 regulations, which mandate that institutions return unearned Title IV funds within 45 days of the date the institution determined the student withdrew. Questioned Costs: None. Context: During the testing performed, it was noted for one student, the Title IV funds were returned 84 days after the withdrawal determination date. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend the University strengthen controls over the R2T4 return process by implementing a tracking or alert system to flag upcoming R2T4 return deadlines to ensure the 45-day requirement is met and conducting periodic internal audits to monitor compliance and identify any delays in return processing. Views Of Responsible Officials: Management concurs with the finding. The University is revising its procedures to ensure timely processing of all required R2T4 returns and is implementing additional internal controls and monitoring steps to ensure compliance with the 45-day return requirement. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services
Finding 2025-005 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.268, 84.007, 84.063, 84.379 Criteria: Under federal Return to Title IV (R2T4) requirements, when a student receive less Title IV aid than the amount earned, the school must offer the student a post-withdrawal disbursement (PWD) of the earned aid the student did not receive. Condition: In our nonstatistical sample of 20 students tested for R2T4 compliance requirements, we noted two students who were eligible for a post-withdrawal disbursement. However, the University could not provide evidence that it offered the required post-withdrawal disbursement to either student. Cause: The University did not have sufficient internal controls to ensure that all students eligible for post-withdrawal disbursements were appropriately notified. Existing procedures did not require documentation of post-withdrawal disbursement offers or adequate monitoring to verify that offers were issued and retained in the student record. Effect: Failure to properly offer a post-withdrawal disbursement results in noncompliance with federal R2T4 requirements, potentially denying students access to Title IV aid they were entitled to receive. Questioned Costs: None. Context: For the two students where no post-withdrawal disbursement offer could be located by the University, the students were eligible to receive $493 of Pell and $631 of direct unsubsidized loans. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend the University implement documentation controls requiring staff to retain evidence of all post-withdrawal disbursement offers in the student file and develop monitoring or review mechanisms to verify that all required post-withdrawal disbursement offers are completed and documented in compliance with federal regulations. Views Of Responsible Officials: Management concurs with the finding. The University is revising its procedures to ensure all post-withdrawal disbursement offers are properly issued and documented and will implement additional controls and staff training to ensure future compliance with federal R2T4 requirements. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services