FINDING 2025-001 Federal Program Information: Federal Pell Grant Program (ALN: 84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (“ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance is allowed and considered tolerable if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: An instance was identified during the year in which funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: During our testing, we identified an instance of tolerable excess cash held in excess of allowable time frames for the Federal Pell Grant Program. Identification of Repeat Finding: This is a repeat of prior year finding 2024-001. Recommendation: We recommend the University enhance its policies and procedures over the cash management process to ensure that excess cash is returned timely, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible for notifying the Business Office when they initiate award reversals that necessitate a refund. The Business Office has updated procedures so that the related general ledger accounts are reviewed no less than once per week for the full year. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances.
FINDING 2025-002 Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms (34 CFR section 668.56). Condition: For a certain student selected for verification, the information required to be verified did not match the underlying supporting documentation. In addition, the University was unable to provide a complete listing of students selected for verification. Cause: Administrative oversight and insufficient internal control. Effect: The University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 1 of 6 students selected for verification testing, the University did not perform appropriate verification procedures. Identification of Repeat Finding: This is a repeat of prior year finding 2024-002. Recommendation: We recommend the University enhance its procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: We have implemented a new Quality Assurance Measure for Auditing all students selected for verification. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and verification has been completed. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and verification steps and then update the verification status to verified and the communication code to audited.
FINDING 2025-003 Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition: Certain borrowers did not receive a loan disbursement notification, or the University was unable to provide a copy of the loan disbursement notification sent to the student. Cause: Administrative oversight and insufficient internal control. Effect: Students and/or parents were not properly notified of loan disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 6 of 40 disbursements tested, the University was unable to provide documentation evidencing an appropriate loan disbursement notification was sent. For 14 of 40 disbursements tested, the corresponding notification was not sent within the required timeframe. Identification of Repeat Finding: This is a repeat of prior year finding 2024-004. Recommendation: We recommend the University enhance its procedures and internal controls over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: We implemented a process which assigns communications management codes based on transmittal activity of each federal direct loan. On the same day a loan is disbursed, our system applies the appropriate code to the student record. These codes are then automatically selected for the correct loan disbursement notification to be sent either to the student or parent based on the federal loan type.
FINDING 2025-004 Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: The University did not properly calculate the amount to be returned for a certain student tested. Cause: Administrative oversight. Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Below reportable threshold. Context: For 1 of 6 students tested, the University did not properly calculate the amount of Title IV aid to be returned. Identification of Repeat Finding: This is a repeat of prior year finding 2024-006. Recommendation: We recommend the University enhance its policies and procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately and funds are returned to the ED within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: We will implement a second check process after R2T4 has been calculated to ensure the correct dates are being used. Chad Wick, Director, Financial Aid will conduct the initial calculating of R2T4 on a weekly basis. Brandon Rhone, Systems Administrator, will review all calculations prior to processing them in Colleague.
FINDING 2025-005 Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – In accordance with 34 CFR 668.133(a)(1)(i), an institution shall require the student to produce the documentation required under the citizenship and residency requirements at § 668.33(a)(2) and request the U.S. Department of Homeland Security to perform secondary confirmation for a student claiming eligibility under § 668.33(a)(2), in accordance with the procedures set forth in § 668.135, if the institution receives an output document indicating that the student must provide the institution with evidence of the student’s immigration status required under § 668.33(a)(2). Condition: During our testing, we identified a student whose immigration status was not confirmed prior to the disbursement of aid. Cause: Administrative oversight and insufficient internal control. Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Questioned Costs: Below reportable threshold. Context: For 1 of 40 students tested, the University did not appropriately assess the student’s eligibility prior to disbursing Title IV awards. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls to ensure that Title IV aid is properly awarded. Views of Responsible Officials and Planned Corrective Actions: We have implemented a new Quality Assurance Measure for Auditing all students with a C-Flag. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and all steps have been completed to clear the C-Flag. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and steps needed to clear C-Flag and then update the communication code to audited and make any adjustments if needed to the FAFSA.
FINDING 2025-006 Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations, 34 CFR 690.83, require the University to submit origination records for students to the Common Origination and Disbursement System (“COD”). Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: For certain disbursements identified through our testing, errors were identified in key items reported to the COD in student origination records. Cause: Administrative oversight and insufficient control. Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: For 6 of 40 origination records tested, the academic end date was not accurately reported. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls over COD reporting to ensure origination record data is accurately reported. Views of Responsible Officials and Planned Corrective Actions: To resolve the finding of loan period academic end dates being inaccurately reported, we now utilize system forms that allow us to identify and batch-correct any student record with incorrect dates. This process enhances data accuracy, ensures proper reporting, prevents COD rejects and reduces the risk of future compliance issues.
FINDING 2025-007 Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Federal regulations, 34 CFR 668.164(i)(1)(i), dictate that the earliest an institution may disburse Title IV, HEA funds to an eligible student or parent is 10 days before the first day of classes of a payment period if the student is enrolled in a credit-hour program offered in terms that are substantially equal in length that is not a subscription-based program. Condition: During our testing, we identified a student whose aid was disbursed outside of the allowable timeframe. Cause: Administrative oversight and insufficient control. Effect: The University was not in compliance with the requirements of disbursing Title IV funds. Questioned Costs: None. Context: For 1 of 25 students tested, the University disbursed Title IV funds earlier than 10 days prior to term start. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls over disbursing Title IV to ensure appropriate timing of disbursements. Views of Responsible Officials and Planned Corrective Actions: We have revised our award period start and end dates to align or fall within range of our loan period code start and end dates when reporting to COD. This alignment ensures that all reported disbursements meet federal timing requests and reduces the risk of COD rejects or compliance findings.