Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Numbers: P007A243144, P063P241946, P033A243144, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), 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 must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition: During our testing, it was noted that an R2T4 calculation was not completed. Questioned Costs: N/A Context: One out of seven students selected for testing should have had a R2T4 calculation completed upon withdrawing from the University. Cause: The University’s controls over performing R2T4 calculations were not functioning as designed. Effect: The University is not following guidelines to calculate and return funds depending upon the date of the student’s withdrawal. Repeat Finding: Yes, 2024-005 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P241946, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students’ enrollment information was not accurately or timely reported to the NSLDS. Questioned Costs: N/A Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following: • One out of forty students were reported to the NSLDS with the incorrect effective date on the campus -level records. • One out of forty students enrollment status was not reported timely. • Seven out of forty students program begin date was not reported accurately to NSLDS. Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace period. Repeat Finding: Yes, 2024-006 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.268 Federal Award Identification Number: P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: In accordance with CFR 685.200(2)(i), a Direct Subsidized Loan borrower must demonstrate financial need in accordance with title IV, part F of the Act. Condition: A student received a Direct Subsidized Loan that did not demonstrate financial need. Questioned Costs: N/A Context: This condition occurred for one out of forty students. Cause: The University’s controls over the awarding of the appropriate aid based off need were not functioning as designed. Effect: A student received Title IV funding for which they were not eligible. Repeat Finding: Yes, 2024-007 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P241946, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Department of Education requires the University to accurately report disbursement dates and disbursement amounts to the Common Origination and Disbursement (COD) system within 15 days of making Pell Grant and Direct Loan disbursements to students, in accordance with federal regulations (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: Certain student loan disbursements were not reported to COD in compliance with federal requirements. Questioned Costs: N/A Context: During our testing of forty disbursements, we noted: • Three out of forty disbursement date errors. • Two out of forty disbursements reported outside of fifteen days. • One out of forty disbursement amount errors. Cause: The University’s controls around reporting to COD were not functioning as designed to ensure timely and accurate reporting. Effect: The University is not in compliance with the Department of Education guidelines. Repeat Finding: Yes, 2024-012 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2025-008: Direct Loan Reconciliations Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Award Identification Number: P268K251946 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly. Condition: Direct loan reconciliations between the COD, G5, and student accounts were not being performed monthly. Questioned Costs: N/A Context: While testing direct loan reconciliations, it was noted that the University did not perform monthly reconciliations for the three months selected for testing. Cause: The University’s process to reconcile direct loans on a monthly basis was not followed during the year. Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled. Repeat Finding: Yes, 2024-013 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A243144, P063P241946, P033A243144, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Federal regulations require that when a Title IV credit balance occurs, the institution must disburse the credit balance to the student or parent within 14 calendar days of the date the credit balance is created, in accordance with 34 CFR 668.164(h)(2). Condition: The University did not refund the student's Title IV credit balance within 14 days period. Questioned Costs: N/A Context: During our testing we noted two out of forty students were not refunded within the fourteen days per federal requirements. Cause: The University’s controls around credit balances were not functioning as designed to ensure timely refunds to students. Effect: The University is not in compliance with the Department of Education guidelines. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around credit balances to ensure that students are refunded within the fourteen day requirement. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During the audit, it was observed that the University did not have adequate segregation of duties in its financial aid office and did not maintain supporting documentation. The Director of Financial Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV funds. Questioned Costs: N/A Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed. There are instances where the Director of Financial Aid is reviewing and approving financial aid packages, reconciliations and other required reports. We also noted instances were supporting documentation could not be provided. Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in inadequate segregation of duties. Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and inaccuracies in awarding and reporting of Title IV funds. Repeat Finding: No Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures. Federal Award Identification Number: P007A243144, P063P241946, P033A243144, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance