Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification: Various Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 1 student enrollment changes where the enrollment status effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 5 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) 3. 1 student enrollment change where status change was not reported to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 6 students with exceptions. 1 student had multiple instances of noncompliance. Cause: The university was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: Yes 2024-001 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Special Tests – Return to Title IV Funds (R2T4) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program 84.007 – Federal Supplemental Educational Opportunity Grants 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification: Various Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution is required to determine the amount of Title IV aid earned as of the student’s withdrawal date. If the amount of Title IV aid earned is less than the amount disbursed to the student or on the student’s behalf as of the date the institution determines the student withdrew, the institution must return the unearned portion to the applicable Title IV programs. No additional disbursements may be made for the payment period or period of enrollment. If the amount of Title IV aid earned exceeds the amount disbursed, the difference must be treated as a post-withdrawal disbursement, in accordance with 34 CFR §668.22(a)(1) through (a)(5). Condition: During our testing of students who ceased attendance during a payment period or period of enrollment—including students who met withdrawal exemptions, dropped courses, took a leave of absence, never began attendance, or otherwise terminated enrollment during the audit period—we selected a sample of 15 students to evaluate the timeliness and accuracy of Return to Title IV (R2T4) calculations and procedures. We identified that the Student Financial Aid system did not calculate R2T4 amounts accurately for 5 of the 15 students tested. In addition, there was insufficient review of system-generated calculations to ensure their accuracy. For these students, the return of funds was not completed within the required 45-day timeframe from the date the institution determined the student withdrew. Questioned costs: $6,644 Context: The University did not properly review system generated calculations. 5 out of the 15 students tested had incorrect calculations and the dates funds were returned not completed withing 45 days of the institution determining the student's withdrawal. Cause: The deficiencies were primarily due to ineffective internal controls over the R2T4 process and errors in system-generated calculations. These issues were further exacerbated by staff turnover that occurred prior to the Fall 2024 term. Effect: As a result, Title IV funds may not have been returned in the correct amounts or within required timeframes, resulting in noncompliance with federal regulations governing the administration of Title IV financial aid programs. Repeat finding: No Recommendation: We recommend that the University strengthen internal controls over the R2T4 process by implementing standardized procedures, ensuring system calculations are accurate, and establishing consistent and documented review of R2T4 calculations prior to the return of Title IV funds. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Eligibility – Direct Loan Awarding Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Numbers: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: P268K240362 2025 Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirements: Direct Subsidized Loans and Direct Unsubsidized Loans are subject to annual loan limits that vary based on a student’s grade level and, for Direct Unsubsidized Loans, dependency status, in accordance with 34 CFR §685.203. The annual loan limit represents the maximum amount a student may receive for an academic year. For undergraduate students, there is a combined annual loan limit for Direct Subsidized and Direct Unsubsidized Loans, of which no more than a specified portion may consist of Direct Subsidized Loans (the “annual subsidized maximum”). Condition: During eligibility testing, we identified one student who was classified as an independent junior and was eligible to receive up to $5,500 in Direct Subsidized Loans. However, the student was awarded only $5,000 in Direct Subsidized Loans. The student was also awarded $7,500 in Direct Unsubsidized Loans, consistent with the applicable annual loan limit. The student’s financial aid package was adjusted using professional judgment; however, an error in recalculation resulted in the student being underawarded $500 in Direct Subsidized Loans and overawarded Direct Unsubsidized Loans by $500. Questioned costs: None. Context: Out of a sample of 41 students tested for eligibility of federal student financial aid awards, the University did not properly award one student the full amount of Direct Subsidized Loan for which the student was eligible. Cause: The error was due to human error during the manual packaging and recalculation process. Effect: The student was underawarded Direct Subsidized Loans and correspondingly overawarded Direct Unsubsidized Loans during the 2024–2025 award year. Repeat finding: No Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ensure student eligibility is accurately determined and awards are properly calculated. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.