Incorrect and Late Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not correctly and timely return all required federal funds when a student withdrew or stopped attending. Criteria: 34 CFR 668.22 Questioned Costs: $2,649 Context: Out of 19 students, 4 students who withdrew during the audit period tested had funds returned late, and 2 students did not have funds returned that should have. One student was not offered a post-withdrawal disbursement when they should have been. Additionally, 6 calculations were not accurate calculations, of which 1 was a modular student. This student had an incorrect R2T4 calculation due to Pell. Pell of $812 should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. These have not yet been corrected. Cause: There were multiple causes of the incorrect and late returns. There were incorrect calendars used, as the University has multiple campuses with different calendars. There was incorrect application of guidance within the attendance taking period before the student withdrew. One student did not have loan fees accounted for within the return, resulting in an under return. The University also experienced turnover in the financial aid department. Effect: Incorrect amounts of federal funding were returned. There were under-returns of Pell of $2,640 and under-returns of subsidized loans of $9. Title IV funds totaling $9,764 were returned late ranging from 3 to 156 days. Identification as repeat finding, if applicable: Yes, 2021-004 and 2020-003. Recommendation: We recommend that the University provide additional training and oversight on R2T4s, with specific emphasis on correct calendars, Pell recalculations, and dates attended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2022-003 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all students. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 76 students tested for proper NSLDS enrollment status, 2 official withdrawal students and 2 unofficial modular withdrawal students had the incorrect effective date for their withdrawal date. The dates ranged from 45 days to 53 days different. There were 5 additional students who withdrew whose enrollment status did not reflect that they had withdrawn. Additionally, 2 students were reported as withdrawn when they attended during the year. The students have not been corrected yet. Cause: The system tracks the data needed for enrollment reporting, but the tool used to pull the data has pieces that were missed which resulted in incomplete and inaccurate data being submitted to NSLDS. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2021-005, 2020-002, and 2019-001. Recommendation: We recommend the University adjust the tool that is used to pull the data from the system to report to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: One student out of 48 was not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $-0- Context: One student added additional classes just before the second module started. These classes were not captured in the enrollment status report used to pay Pell, and resulted in this student being eligible for $1,623 more than they received. This was not corrected during the audit. Cause: The enrollment report was pulled before the start of class, and there was not a second enrollment report to identify differences between those scheduled and those began. Effect: There was an incorrect amount of Pell paid to this student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status and classes in which the student began attendance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The dates and amounts that Pell and FDL awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 1 of 53 tested had COD loan disbursement date error that was 60 days. Eleven of the 48 Pell students tested had COD disbursement date errors ranging from 7-109 days (10 students were 7 days different). These were not corrected during the audit. Cause: For the FDL disbursement, the full amount had been reported to COD at the start of the spring term, while the disbursements were split between the two modules. For the Pell disbursements, the majority were due to rejects or issues on the COD side before they could post. Furthermore, all reconciliations for Pell and FDL are done on screen without a trail of discrepancies or corrections made. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. PowerFAIDS has an import feature that can be used to complete the reconciliations timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect and Late Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not correctly and timely return all required federal funds when a student withdrew or stopped attending. Criteria: 34 CFR 668.22 Questioned Costs: $2,649 Context: Out of 19 students, 4 students who withdrew during the audit period tested had funds returned late, and 2 students did not have funds returned that should have. One student was not offered a post-withdrawal disbursement when they should have been. Additionally, 6 calculations were not accurate calculations, of which 1 was a modular student. This student had an incorrect R2T4 calculation due to Pell. Pell of $812 should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. These have not yet been corrected. Cause: There were multiple causes of the incorrect and late returns. There were incorrect calendars used, as the University has multiple campuses with different calendars. There was incorrect application of guidance within the attendance taking period before the student withdrew. One student did not have loan fees accounted for within the return, resulting in an under return. The University also experienced turnover in the financial aid department. Effect: Incorrect amounts of federal funding were returned. There were under-returns of Pell of $2,640 and under-returns of subsidized loans of $9. Title IV funds totaling $9,764 were returned late ranging from 3 to 156 days. Identification as repeat finding, if applicable: Yes, 2021-004 and 2020-003. Recommendation: We recommend that the University provide additional training and oversight on R2T4s, with specific emphasis on correct calendars, Pell recalculations, and dates attended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2022-003 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all students. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 76 students tested for proper NSLDS enrollment status, 2 official withdrawal students and 2 unofficial modular withdrawal students had the incorrect effective date for their withdrawal date. The dates ranged from 45 days to 53 days different. There were 5 additional students who withdrew whose enrollment status did not reflect that they had withdrawn. Additionally, 2 students were reported as withdrawn when they attended during the year. The students have not been corrected yet. Cause: The system tracks the data needed for enrollment reporting, but the tool used to pull the data has pieces that were missed which resulted in incomplete and inaccurate data being submitted to NSLDS. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2021-005, 2020-002, and 2019-001. Recommendation: We recommend the University adjust the tool that is used to pull the data from the system to report to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students were not initially appropriately awarded subsidized aid based on need. Students were not appropriately awarded subsidized loans based on need. When there was a change in student?s information on the ISIR and a subsequent ISIR was produced, in some instances, the University did not update the student?s federal financial aid awarding to reflect the updated information. Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 685.203 Questioned Costs: $2,000 Context: 5 students out of 60 were not awarded the correct amount of subsidized and unsubsidized loans based on the year of enrollment as defined by the credit hours earned at the University. Of these 5 students, 2 students attended one semester so they were not over-awarded for the whole year. One student was awarded as a senior but was only a sophomore, resulting in $1,000 sub and $1,000 unsub to be returned. The other two students were under-awarded by $4,000. These are not yet corrected. Cause: The University imported the self-reported line from the FAFSA and did not override this field for all students based on credits earned at the time of the awarding. Effect: One student received subsidized and unsubsidized federal aid for which they were not eligible while 2 others did not receive the aid for which they were eligible. Identification as repeat finding, if applicable: Yes, 2021-008. Recommendation: We recommend the University ignore the FAFSA line and only use the credits earned for awarding. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The dates and amounts that Pell and FDL awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 1 of 53 tested had COD loan disbursement date error that was 60 days. Eleven of the 48 Pell students tested had COD disbursement date errors ranging from 7-109 days (10 students were 7 days different). These were not corrected during the audit. Cause: For the FDL disbursement, the full amount had been reported to COD at the start of the spring term, while the disbursements were split between the two modules. For the Pell disbursements, the majority were due to rejects or issues on the COD side before they could post. Furthermore, all reconciliations for Pell and FDL are done on screen without a trail of discrepancies or corrections made. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. PowerFAIDS has an import feature that can be used to complete the reconciliations timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect and Late Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not correctly and timely return all required federal funds when a student withdrew or stopped attending. Criteria: 34 CFR 668.22 Questioned Costs: $2,649 Context: Out of 19 students, 4 students who withdrew during the audit period tested had funds returned late, and 2 students did not have funds returned that should have. One student was not offered a post-withdrawal disbursement when they should have been. Additionally, 6 calculations were not accurate calculations, of which 1 was a modular student. This student had an incorrect R2T4 calculation due to Pell. Pell of $812 should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. These have not yet been corrected. Cause: There were multiple causes of the incorrect and late returns. There were incorrect calendars used, as the University has multiple campuses with different calendars. There was incorrect application of guidance within the attendance taking period before the student withdrew. One student did not have loan fees accounted for within the return, resulting in an under return. The University also experienced turnover in the financial aid department. Effect: Incorrect amounts of federal funding were returned. There were under-returns of Pell of $2,640 and under-returns of subsidized loans of $9. Title IV funds totaling $9,764 were returned late ranging from 3 to 156 days. Identification as repeat finding, if applicable: Yes, 2021-004 and 2020-003. Recommendation: We recommend that the University provide additional training and oversight on R2T4s, with specific emphasis on correct calendars, Pell recalculations, and dates attended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2022-003 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all students. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 76 students tested for proper NSLDS enrollment status, 2 official withdrawal students and 2 unofficial modular withdrawal students had the incorrect effective date for their withdrawal date. The dates ranged from 45 days to 53 days different. There were 5 additional students who withdrew whose enrollment status did not reflect that they had withdrawn. Additionally, 2 students were reported as withdrawn when they attended during the year. The students have not been corrected yet. Cause: The system tracks the data needed for enrollment reporting, but the tool used to pull the data has pieces that were missed which resulted in incomplete and inaccurate data being submitted to NSLDS. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2021-005, 2020-002, and 2019-001. Recommendation: We recommend the University adjust the tool that is used to pull the data from the system to report to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: One student out of 48 was not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $-0- Context: One student added additional classes just before the second module started. These classes were not captured in the enrollment status report used to pay Pell, and resulted in this student being eligible for $1,623 more than they received. This was not corrected during the audit. Cause: The enrollment report was pulled before the start of class, and there was not a second enrollment report to identify differences between those scheduled and those began. Effect: There was an incorrect amount of Pell paid to this student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status and classes in which the student began attendance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The dates and amounts that Pell and FDL awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 1 of 53 tested had COD loan disbursement date error that was 60 days. Eleven of the 48 Pell students tested had COD disbursement date errors ranging from 7-109 days (10 students were 7 days different). These were not corrected during the audit. Cause: For the FDL disbursement, the full amount had been reported to COD at the start of the spring term, while the disbursements were split between the two modules. For the Pell disbursements, the majority were due to rejects or issues on the COD side before they could post. Furthermore, all reconciliations for Pell and FDL are done on screen without a trail of discrepancies or corrections made. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. PowerFAIDS has an import feature that can be used to complete the reconciliations timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect and Late Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not correctly and timely return all required federal funds when a student withdrew or stopped attending. Criteria: 34 CFR 668.22 Questioned Costs: $2,649 Context: Out of 19 students, 4 students who withdrew during the audit period tested had funds returned late, and 2 students did not have funds returned that should have. One student was not offered a post-withdrawal disbursement when they should have been. Additionally, 6 calculations were not accurate calculations, of which 1 was a modular student. This student had an incorrect R2T4 calculation due to Pell. Pell of $812 should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. These have not yet been corrected. Cause: There were multiple causes of the incorrect and late returns. There were incorrect calendars used, as the University has multiple campuses with different calendars. There was incorrect application of guidance within the attendance taking period before the student withdrew. One student did not have loan fees accounted for within the return, resulting in an under return. The University also experienced turnover in the financial aid department. Effect: Incorrect amounts of federal funding were returned. There were under-returns of Pell of $2,640 and under-returns of subsidized loans of $9. Title IV funds totaling $9,764 were returned late ranging from 3 to 156 days. Identification as repeat finding, if applicable: Yes, 2021-004 and 2020-003. Recommendation: We recommend that the University provide additional training and oversight on R2T4s, with specific emphasis on correct calendars, Pell recalculations, and dates attended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2022-003 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all students. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 76 students tested for proper NSLDS enrollment status, 2 official withdrawal students and 2 unofficial modular withdrawal students had the incorrect effective date for their withdrawal date. The dates ranged from 45 days to 53 days different. There were 5 additional students who withdrew whose enrollment status did not reflect that they had withdrawn. Additionally, 2 students were reported as withdrawn when they attended during the year. The students have not been corrected yet. Cause: The system tracks the data needed for enrollment reporting, but the tool used to pull the data has pieces that were missed which resulted in incomplete and inaccurate data being submitted to NSLDS. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2021-005, 2020-002, and 2019-001. Recommendation: We recommend the University adjust the tool that is used to pull the data from the system to report to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students were not initially appropriately awarded subsidized aid based on need. Students were not appropriately awarded subsidized loans based on need. When there was a change in student?s information on the ISIR and a subsequent ISIR was produced, in some instances, the University did not update the student?s federal financial aid awarding to reflect the updated information. Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 685.203 Questioned Costs: $2,000 Context: 5 students out of 60 were not awarded the correct amount of subsidized and unsubsidized loans based on the year of enrollment as defined by the credit hours earned at the University. Of these 5 students, 2 students attended one semester so they were not over-awarded for the whole year. One student was awarded as a senior but was only a sophomore, resulting in $1,000 sub and $1,000 unsub to be returned. The other two students were under-awarded by $4,000. These are not yet corrected. Cause: The University imported the self-reported line from the FAFSA and did not override this field for all students based on credits earned at the time of the awarding. Effect: One student received subsidized and unsubsidized federal aid for which they were not eligible while 2 others did not receive the aid for which they were eligible. Identification as repeat finding, if applicable: Yes, 2021-008. Recommendation: We recommend the University ignore the FAFSA line and only use the credits earned for awarding. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The dates and amounts that Pell and FDL awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 1 of 53 tested had COD loan disbursement date error that was 60 days. Eleven of the 48 Pell students tested had COD disbursement date errors ranging from 7-109 days (10 students were 7 days different). These were not corrected during the audit. Cause: For the FDL disbursement, the full amount had been reported to COD at the start of the spring term, while the disbursements were split between the two modules. For the Pell disbursements, the majority were due to rejects or issues on the COD side before they could post. Furthermore, all reconciliations for Pell and FDL are done on screen without a trail of discrepancies or corrections made. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. PowerFAIDS has an import feature that can be used to complete the reconciliations timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.