Criteria Under 34 CFR 668.162(b)(1) and (b)(3), an institution participating in the Title IV programs under the advance payment method may request only the amount of federal funds needed for immediate disbursement to eligible students and parents, and must disburse those funds as soon as administratively feasible, but no later than three business days after receipt. Additionally, under 34 CFR 668.24(b)(2)(i)-(ii) and 668.24(d)(1), institutions are required to establish and maintain financial records, including general ledger control accounts and related subsidiary accounts, that accurately reflect each Title IV transaction and are systematically organized to support compliance and examination. Finally, pursuant to 2 CFR 200.303, institutions must establish, document, and maintain effective internal controls over federal awards to provide reasonable assurance of compliance with applicable federal statutes, regulations, and award terms, including monitoring compliance and taking prompt corrective action when instances of noncompliance are identified. Condition The University does not maintain sufficient supporting documentation to directly reconcile G5 drawdowns to specific Title IV student-level disbursements. Although reconciliations are performed on an overall basis, they do not provide sufficient detail to establish a direct correlation between individual student disbursements and related drawdowns. Therefore, the three-business day requirement could not be tested. Cause The condition resulted from internal controls over Title IV cash management that were not fully defined or implemented following the recent ERP transition to Ellucian Banner. Specifically, the University lacks a system-generated report that provides student-level disbursement detail segregated by Title IV program (e.g. Pell Grant, FSEOG, Direct Loans) needed to reconcile disbursement activity on a per-student basis to the G5 drawdown activity. During the transition, the University relied on manual, undocumented procedures and unreconciled reports to request funds. Effect The absence of detailed reconciliation documentation limits the University’s ability to clearly demonstrate compliance with federal Cash Management requirements under 34 CFR Part 668 Subpart K - Cash Management. This condition increases the risk that cash management discrepancies may not be identified on a timely basis. Questioned Costs None. Recommendation We recommend the University formalize and implement a Title IV cash management reconciliation process in accordance with 34 CFR 668.162, 668.166, 668.24, and 2 CFR 200.303. This process should require timely reconciliation of each G5 drawdown to specific Title IV disbursements at the student level, with clearly defined roles, responsibilities, and documentation requirements. The University should enhance system or supplemental reporting to support student-level linkage of drawdowns to disbursements and implement controls to monitor excess cash, including compliance with the three-business-day rule and applicable tolerance thresholds. Additionally, supporting documentation should be retained in an organized manner, and supervisory review, periodic monitoring, and staff training should be established to ensure ongoing compliance. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 34 CFR 668.165(a)(3)(i), an institution must provide the required written notice of the Direct Loan disbursement no earlier than thirty (30) days before and no later than thirty (30) days after crediting the student’s ledger account, if the institution has obtained affirmative confirmation from the student as provided in 34 CFR 668.165(a)(6)(i). Condition From a sample of twenty-nine (29) students who received Direct Loans, we identified three (3) instances, pertaining to the Fall 2024 academic session, where the required written disbursement notification was not issued to each student. Cause The condition resulted from the inconsistent application of disbursement procedures during a period in which the University was transitioning to its new ERP system, Ellucian Banner. During this transition, the University had not yet fully defined or formalized the monitoring process needed to ensure that required written disbursement notices for Direct Loan recipients were generated and issued in accordance with established procedures. Effect The failure to provide the mandatory written disbursement notifications within the prescribed timeframe resulted in noncompliance with federal requirements. Consequently, affected borrowers were not formally notified of their right to cancel or reduce their loan disbursements within the required notification period. Questioned Costs None. Recommendation We recommend that the University design and implement formal monitoring procedures to ensure that required Direct Loan disbursement notifications are issued after each disbursement run. This may include establishing periodic supervisory checks, exception reports, or other controls to verify that the notification step was completed as intended and in accordance with federal requirements. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 34 CFR 668.164(h)(2)(i), a Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than fourteen (14) days after the credit balance occurs, if the credit balance arises after the first day of class of the payment period. Condition From a sample of seventeen (17) students with Title IV credit balances subject to the fourteen (14) days refund requirement, we identified thirteen (13) students with at least one instance of a late refund, totaling 14 instances in which credit balance refunds were not issued within the required timeframe. Cause The condition occurred because, during the academic year 2024–2025, the University transitioned to a new ERP system, Ellucian Banner, introducing new and modified processes that required additional training. Concurrently, responsibility for key post-disbursement activities shifted from the Accounting office to the Bursar & Collections office, requiring new coordination between both areas. Although the University had defined a monitoring process among the cross-functional offices involved in tracking Title IV credit balances, including a calendar outlining required activities and the timelines each department must follow after the disbursement run, the Bursar office, as it assumed these expanded responsibilities, faced an adjustment period and did not have sufficient staffing to execute these procedures consistently within required timeframes during the transition period. Effect The failure to disburse credit balances within the prescribed regulatory period resulted in noncompliance with federal requirements. Consequently, affected students did not receive timely access to their Title IV funds, as required. Questioned Costs None. Recommendations We recommend that the University evaluate and address the staffing limitations within the department responsible for key post-disbursement monitoring procedures. This may include allocating temporary support, reallocating internal personnel during peak periods, or reviewing workload distribution to ensure all required tasks outlined in the monitoring calendar are completed timely. Additionally, Management should implement a contingency plan for periods of reduced staffing to ensure continuity of the established monitoring process and prevent delays in processing Title IV credit balance refunds. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 34 CFR 690.83(b), 34 CFR 685.309(b)(1) and (b)(2)(i), and 34 CFR 682.610(c)(2)(i), institutions participating in the Title IV Direct Loan and FFEL programs must timely report and update student enrollment information to the U.S. Department of Education. Specifically, institutions are required to update and return enrollment reports received from the Secretary in the prescribed format and within the prescribed timeframe, and must notify the Secretary within thirty (30) days after determining that a student who received a Title IV loan has ceased to be enrolled at least half-time or failed to enroll as intended, unless the next scheduled enrollment report will be submitted within sixty (60) days. Condition From a sample of twenty (20) withdrawn students selected for the National Student Loan Data System (NSLDS) enrollment report testing, three (3) instances were identified in which the students’ withdrawal status and corresponding change in enrollment were not reported to the U.S. Department of Education within the required time-frame. Withdrawals occurred during the Winter and Spring academic sessions of the 2024–2025 academic year. This is a repeat finding. Refer to finding 2024-006. Cause The condition occurred because the parameters used within the Ellucian Banner system to generate the enrollment extract submitted to the National Student Clearinghouse (NSC) were not configured correctly. As a result, certain students were inadvertently excluded from the extract file, and consequently, their student status changes were not reported to the NSLDS in subsequent enrollment reporting cycles. Effect The failure to report changes in enrollment status resulted in noncompliance with federal requirements. Consequently, student enrollment information in NSLDS is not accurate, affecting the timing of borrowers’ grace periods, repayment status, or related loan servicing updates. Questioned Costs None. Recommendation We recommend that the University review and strengthen the configuration controls related to the Ellucian Banner system parameters used to generate enrollment extracts for submission to the National Student Clearinghouse. This should include implementing a formal process to validate that the extract parameters accurately capture the full population of reportable students prior to each submission. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 34 CFR 685.300(b)(5), on a monthly basis, the Institution must reconcile institutional records with Direct Loan funds received and Direct Loan disbursement records submitted to and accepted by the Secretary of Education. Condition The University did not perform the required monthly Direct Loan reconciliations for Academic Year 2024-2025. Cause The condition occurred because during academic year 2024-2025, the University was in the process of transitioning from its previous ERP system, including financial aid module, to a new system, Ellucian Banner. Under the new system, the reconciliation process was not clearly defined, not formally documented, and not consistently executed during a portion of the academic year, which affected the normal reconciliation process, including the retention of supporting documentation. Effect The condition resulted in inconsistent execution of reconciliation procedures and an inability to demonstrate that the University's Direct Loan records align with federal records, increasing the risk of undetected discrepancies. Consequently, it led to actual noncompliance in the months where reconciliations were not performed, as well as potential noncompliance for months in which no documentation was retained to evidence completion. Questioned Costs None. Recommendation We recommend that the University establish and implement a documented process to ensure all required monthly Direct Loan reconciliations are prepared, reviewed, and that the supporting evidence is retained in accordance with federal requirements. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 34 CFR 646.3(d), the TRIO Student Support Services (SSS) program requires that, at the time of admission, each participant meet at least one of the following eligibility criteria: be a low-income individual, a first-generation college student, or an individual with disabilities. This requirement is established under Program regulations at 34 CFR 646.7 define an “individual with a disability” by reference to the Americans with Disabilities Act (ADA), 42 U.S.C. 12102, which defines a disability as a physical or mental impairment that substantially limits one or more major life activities, a record of such impairment, or being regarded as having such an impairment. Condition During our review of TRIO participant eligibility, we identified one (1) participant admitted under the disability eligibility criteria. The participant file included a doctor’s note describing a moderate to high level of refractive errors (hypermetropia and astigmatism) in both eyes and recommending corrective lenses (with UV 400, Anti-reflective and blue light filter). However, the documentation did not demonstrate a substantial limitation of a major life activity under the ADA framework. In addition, the participant did not qualify under the low-income or first-generation criteria at the time of admission. Therefore, the participant did not meet any TRIO eligibility criteria at the time of entry into the program. Cause The condition occurred because the University relied on limited documentation provided by the applicant to assess whether the evidence supported or not a disability status under the ADA definition prior to admission. Additionally, existing procedures did not ensure that eligibility determinations were based solely on documentation available at the time of program entry. Furthermore, there was no secondary or supervisory review to ensure eligibility was properly supported prior to admission. Effect The lack of appropriate eligibility assessment led to the admission of an ineligible participant into the TRIO program and the provision of associated services, resulting in noncompliance with federal requirements. Questioned Costs None. Recommendation We recommend that the University strengthen its TRIO participant eligibility review process to ensure that all students admitted to the program under the disability criteria provide appropriate supporting evidence of the disability and demonstrate that the disability results in a substantial limitation of a major life activity, in accordance with applicable federal definitions. In addition, the University should implement an independent supervisory review of disability determinations. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 2 CFR 200.319, all procurement transactions must provide full and open competition and avoid restrictive practices. Additionally, 2 CFR 200.318 requires entities to maintain oversight of contractor performance and document procurement history in accordance with written standards. Condition From a sample of sixty-eight (68) Title V disbursements reviewed, three (3) instances were identified in which the procurement method applied and related supporting documentation were not adequately aligned with federal procurement standards. Specifically, the University utilized sole-source providers for certain purchases where the rationale provided was unsuitable since it did not sufficiently explain why alternative vendors were not considered. Cause The condition resulted from inadequate procurement documentation and insufficient enforcement of competitive procurement practices. While procurement activities were conducted, the University did not consistently document the justification for sole-source selections or demonstrate that full and open competition was considered. Additionally, procurement review and oversight controls were not consistently applied, leading to incomplete procurement histories and insufficient support for vendor selection decisions. Effect The procurement transactions identified resulted in noncompliance with federal requirements. While the procurement methods used did not fully comply with federal competition requirements, no evidence indicates that the related costs were unreasonable or unallowable. However, continued noncompliance could result in disallowed costs or increased administrative oversight by the U.S. Department of Education, including potential reconsideration of the University’s eligibility to operate under the advance payment. Questioned Costs None. Recommendation We recommend that the University update its procurement policies and related procedures to clearly and further define federal procurement methods, thresholds, and required documentation, and to consistently enforce them. Additionally, the evidence to document the use of sole provider justification must clearly state the unique nature of the source, any urgent circumstances, specific authorizations, and efforts to solicit competition in accordance with 2 CFR Part 200. Views of Responsible Officials Refer to Management's unaudited corrective action plan.
Criteria Under 2 CFR 200.305(b), the non-Federal entity must minimize the time between the receipt of federal funds and their disbursement, limiting advances to immediate cash needs. Additionally, 2 CFR 200.302(b) requires the non-Federal entity must maintain financial management systems that provide accurate, current, and complete disclosure of financial results and permit the tracing of federal funds to ensure they are used in accordance with applicable federal requirements. Condition Higher Education Institutional Aid From a sample of sixty-eight (68) disbursements selected for testing, the following were identified: Eight (8) instances in which the elapsed time between receipt of federal funds and the related disbursement exceeded three (3) business days. Six (6) instances in which vendor payments could not be traced to a corresponding federal funding request due to lack of supporting documentation. One (1) instance where the disbursement was requested twice within two separate federal funding requests. TRIO Cluster From a sample of ten (10) disbursements selected for testing, the following were identified: Three (3) instances in which disbursements could not be traced to a corresponding federal funding request due to lack of supporting documentation. One (1) instance where the disbursement was requested twice within two separate federal funding requests. This is a repeat finding. Refer to finding 2024-002. Cause The condition occurred because the existing cash management process does not contain the level of detail or structure needed to ensure federal cash activity is fully and consistently accounted for. Also, the University lacks clearly defined monitoring procedures to ensure federal cash transactions were timely processed. Effect The instances where disbursements occurred for more than three business days after receipt of federal funds, and the instance where the same disbursement was considered in two separate drawdowns, resulted in actual noncompliance with federal cash management requirements. In addition, for instances where vendor payments could not be traced to a specfic funds request, the University is unable to substantiate compliance with federal requirements, resulting in potential noncompliance. Continued noncompliance could result in additional administrative oversight by the U.S. Department of Education, including potential reconsideration of the University’s eligibility to operate under the advance payment method. Questioned Costs None. Recommendation We recommend that the University strengthen its reconciliation procedures, including enhancing the content and review of the Funds Request Form and consistently retaining appropriate documentation for each federal funding request. Additionally, the University should establish monitoring procedures, such as periodic reviews of federal cash balances and funding requests, to ensure that disbursements are issued within regulatory timeframes. Views of Responsible Officials Refer to Management's unaudited corrective action plan.