Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Agency: Department of Education (DOE) Federal Award Numbers: Unknown; Award Year: 2025 Criteria: Per 34 CFR §674.19(e), institutions participating in the Federal Perkins Loan Program are required to maintain loan documentation, including properly executed promissory notes and repayment records, for each loan. Such records must be retained until the loan is satisfied, assigned to the U.S. Department of Education, or otherwise resolved, with certain repayment documentation retained for a minimum period following loan resolution. Condition: During prior year testing of Perkins loan documentation, the following exceptions were identified from a sample of 25 loans: 1. 3 of 25 loans did not have a signed promissory note on file. 2. 24 of 25 loans did not have adequate repayment documentation maintained. Due to the nature of the requirement and the extended document retention period, the conditions noted above continue to represent noncompliance with federal requirements. Cause: Turnover within the financial aid and related administrative departments resulted in a lack of continuity in maintaining Perkins loan documentation. Effect: The absence of promissory notes and repayment documentation increases the risk that the institution cannot support loan balances, enforce repayment in the event of default, or demonstrate compliance with federal program requirements. This may result in potential liability, including required assignment of loans to the U.S. Department of Education. Questioned Costs: None reported Context: The prior year exceptions reflect deficiencies in maintaining required Perkins loan documentation across a significant portion of the population tested. Due to the long-term retention requirements associated with Perkins loans, these deficiencies remain relevant in the current year. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure Perkins loan documentation is maintained according to requirements. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007 Federal Agency: Department of Education (DOE) Federal Award Numbers: P007A243392; Award Year: 2025 Criteria: Pursuant to 34 CFR 668.164 and 34 CFR 668.165, institutions must disburse Title IV funds by crediting the funds to the student’s account for allowable charges within the applicable payment period. Condition: During testing, it was noted that the Institution applied $85,880 of SEOG funding related to the 2024–2025 award year to student accounts during fiscal year 2026. These funds were not awarded or disbursed during the applicable award year due to the Institution not initially allocating the full amount of available SEOG funding to eligible students. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in processes related to timely awarding of aid Effect: As a result, SEOG funds were disbursed outside of the applicable award year, resulting in noncompliance with federal program requirements related to the timing of disbursements. Questioned Costs: Questioned costs of $85,880 are associated with this finding, as the allowability of these late disbursements is not in accordance with program requirements. Context: Controls did not operate properly for the University to timely and accurately apply federal aid. Repeat Finding: No Recommendations: We recommend that the University evaluate its processes and controls to ensure federal aid disbursement are completed timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Federal Award Numbers: P063P242023, P268K252023; Award Year: 2025 Criteria: Per 34 CFR §668.164(a) and related Department of Education guidance, institutions are required to submit accurate disbursement records for Federal student aid programs to the Common Origination and Disbursement (COD) system within 15 calendar days of the disbursement date or becoming aware of the need to adjust a disbursement. Additionally, per 34 CFR §668.16(b) and 34 CFR §673.3, institutions are required to establish and maintain administrative and fiscal procedures to ensure proper and accurate reporting of Title IV program activity, including the accurate preparation and submission of the Fiscal Operations Report and Application to Participate (FISAP). Condition: During our testing of reporting compliance, we identified the following: 1. COD Reporting: For 2 of 37 Federal Direct Loan awards tested, the student's aid year and/or cost of attendance was incorrectly reported to COD. 17 of 17 Pell Grant fall disbursements tested were not reported to COD within the required 15-day period. 2 of 37 Federal Direct Loan disbursements tested were not reported within the required timeframe. The sample was not intended to be, and was not, a statistically valid sample. 2. FISAP Reporting: The FISAP was not initially prepared and submitted accurately, resulting in the need for subsequent correction. In addition, management was unable to provide supporting documentation for various information that was reported in the FISAP. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in established reporting processes. Effect: Failure to report disbursement data timely to COD and to accurately prepare and submit the FISAP may result in noncompliance with federal requirements and may affect the reliability of information reported to the U.S. Department of Education. Questioned Costs: None reported Context: The exceptions identified above represent deviations from federal reporting requirements across both real-time (COD) and periodic (FISAP) reporting processes within the Student Financial Assistance Cluster. Repeat Finding: Yes Recommendations: The University should evaluate its processes and controls to ensure reporting is completed accurately and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Under the GLBA Safeguards Rule, entities serving in the capacity of financial institutions must develop, implement, and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards. Condition: The institution has not fully implemented or documented controls as required by the GLBA. Specifically, based on testing we noted that: • Customer data is not encrypted • Periodic inventories of data were not performed for the period 7/1/2024-3/1/2025 • While an annual risk assessment was performed, which included required elements, many of those elements were not found to be satisfactorily implemented for all or part of the year. Cause: The institution did not have adequate internal controls or monitoring procedures in place to ensure compliance with the GLBA Act. Effect: Failure to implement and enforce access controls increases the risk of unauthorized access to sensitive customer data, potentially leading to data breaches, regulatory penalties, and reputational harm. Questioned Costs: None reported Context: Controls did not operate properly for the University to comply with requirements of the GLBA Act. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure all requirements of GLBA are monitored and addressed. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Federal regulations require institutions to pay Title IV credit balance refunds to students or parents as soon as possible, but no later than 14 days after the credit balance occurs. In addition, institutions must establish and maintain on a current basis, financial records that reflect each Title IV program transaction; and general ledger control accounts and related subsidiary accounts that identify each Title IV program transaction and separate those transactions from all other institutional financial activity in accordance with 34 C.F.R, 668.24(b)(2). Condition: During our review, we identified 5 of 40 student credit balance refunds that were processed outside of the required 14-day timeframe. Controls for proper review and approval of these refunds were not in place during the entire year under audit. In addition, the University was unable to produce a report to specifically identify which credit balances were attributable to federal financial assistance, as opposed to institutional, state, or other non-federal sources. The sample was not intended to be, and was not, a statistically valid sample. Cause: The institution did not have adequate internal controls or monitoring procedures in place to ensure compliance with credit balance requirements Effect: The University did not fully comply with federal Title IV requirements. Failure to timely process credit balance refunds and to properly identify federal aid credit balances increases the risk of noncompliance, potential regulatory findings, and possible enforcement actions by the U.S. Department of Education. Questioned Costs: None reported Context: Controls did not operate properly for the University to comply with requirements for disbursements to and on behalf of students. Repeat Finding: Yes Recommendations: We recommend that the University implement proper processes and controls to ensure all credit balances resulting from federal aid are properly identified and returned timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.063, 84.268 Federal Agency: Department of Education (DOE) Federal Award Numbers: P007A243392, P063P242023, P268K252023; Award Year: 2025 Criteria: Federal regulations require institutions to minimize the time between the drawdown of federal funds and their disbursement to students, and to ensure that drawdowns do not exceed immediate cash needs. Institutions must maintain adequate internal controls to ensure federal funds are not drawn in excess of amounts needed for disbursement. Condition: During testing, it was noted that the University drew down Student Financial Assistance funds in excess of immediate disbursement needs at various points throughout the year. Specifically: • Pell Grant funds of up to $35,531 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $4,224 remained overdrawn as of June 30, 2025. • SEOG funds of up to $120,508 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $120,508 remained overdrawn as of June 30, 2025. • Federal Direct Loans of up to $351,211 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $73,597 remained overdrawn as of June 30, 2025. Cause: The University did not have adequate monitoring controls in place to ensure that drawdowns were limited to immediate cash needs and that fund balances were reconciled timely and accurately across programs. Testing indicated reconciliations were not routinely performed between the University's systems and federal systems, resulting in these errors. Effect: The University was not in compliance with federal cash management requirements, as federal funds were drawn in excess of allowable amounts. This increases the risk of improper cash management and potential noncompliance with Department of Education regulations. Questioned Costs: None reported Context: Testing identified multiple instances of overdrawn fund positions across the SEOG, Federal Direct Loan, and Pell programs throughout the fiscal year, occurring at various points in time and in varying amounts. Overdrawn conditions were not isolated to a single period or program but were observed intermittently across all three programs. At fiscal year-end, two of the three programs tested (SEOG and Federal Direct Loan) remained in an overdrawn position, while the Pell program was resolved prior to year-end. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure cash draws are completed for appropriate amounts. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P268K252023; Award Year: 2025 Criteria: Per 34 CFR §668.22, institutions are required to perform Return of Title IV (R2T4) calculations when a student withdraws and must return any unearned Title IV funds within 45 days of the date the institution determines the student withdrew. Institutions are also required to accurately calculate the amount of aid earned by the student and the amount required to be returned. Condition: The institution did not consistently perform R2T4 calculations during the year. As a result: 1. 3 of the 4 students tested had R2T4 calculations that were performed late, resulting in $14,074 of returned funds outside the required timeframe. 2. Of the R2T4 calculations tested, 4 of 4 students had R2T4 calculations that were performed incorrectly, resulting in $691 of net over returned Title IV aid. The sample was not intended to be, and was not, a statistically valid sample. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in processes related to identifying withdrawn students and completing R2T4 calculations. Effect: Failure to perform timely and accurate R2T4 calculations resulted in noncompliance with federal regulations. Late returns may subject the institution to increased scrutiny, potential liabilities, and interest assessments. Inaccurate calculations result in improper return amounts, impacting both the U.S. Department of Education and affected students. Questioned Costs: $691 related to inaccurate calculations (over/under-returned aid). Context: The University did not have proper controls in place to complete R2T4 calculations timely or accurately. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure R2T4 calculations are completed accurately and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Under 2 CFR §200.512 (Uniform Guidance), auditees must submit the reporting package and Data Collection Form (DCF) to the Federal Audit Clearinghouse within 30 calendar days after receipt of the auditor’s report, but no later than nine months after the end of the audit period. Condition: The University submitted the DCF after the required deadline: DCF due date: 3/31/2026 No documented extension or waiver was obtained. Status of DCF and audit was questioned by funding source. Cause: The institution did not have adequate internal controls or monitoring procedures in place to timely submit the DCF. Effect: Increased risk of federal oversight or sanctions for repeated late filings. Questioned Costs: None reported Context: Controls did not operate properly for the University to timely submit the DCF. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure DCF filings are completed timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Institutions are required to perform verification procedures for students selected for verification by the U.S. Department of Education (ED), including obtaining required documentation, comparing the information to the student’s FAFSA data, making necessary corrections, and updating verification status, in accordance with 34 CFR 668.51–668.60 and the OMB Compliance Supplement. Condition: During testing of students selected for verification, we noted that 2 of 3 students tested did not have evidence that required verification procedures were performed. Specifically, the institution did not obtain or document supporting verification information or complete required comparison and correction procedures for this student. Additionally, controls to track verification processes were being completed timely and accurately were not operating during the academic year. The sample was not intended to be, and was not, a statistically valid sample. Cause: The condition is attributable to turnover within the Student Financial Assistance office during the year, which resulted in gaps in personnel responsible for performing and monitoring verification procedures. As a result, the institution did not maintain effective oversight or continuity in its verification processes to ensure that all students selected for verification had required procedures completed and documented. Effect: Failure to perform required verification procedures may result in the disbursement of Title IV funds based on inaccurate or unverified student information, increasing the risk of improper payments and noncompliance with federal requirements. Questioned Costs: None reported Context: Failure to perform verification procedures for students selected by the U.S. Department of Education represents noncompliance within the “Special Tests and Provisions—Verification” compliance requirement and increases the risk that aid may be awarded based on incomplete or inaccurate information. Repeat Finding: No Recommendations: We recommend that the University evaluate its processes and controls to ensure verifications are properly performed and documented. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Institutions participating in the Title IV programs are required to report enrollment status changes, including student withdrawals, to the National Student Loan Data System (NSLDS) accurately and within the required reporting timeframe. Enrollment information must reflect the student's actual effective date of withdrawal and be reported no later than 60 days from the date the institution becomes aware of the status change. Condition: Of the forty student records tested for NSLDS withdrawal reporting, we identified the following: • One student where the effective date of withdrawal was reported as the end of the semester rather than the student's actual withdrawal date. • Six students where the effective date of withdrawal was reported as the date the student was notified rather than the actual effective withdrawal date. • One student where the student's withdrawal was not reported timely and was not included on the first enrollment roster following the withdrawal. As a result, eight student records contained inaccurate or untimely withdrawal reporting information submitted to NSLDS. The sample was not intended to be, and was not, a statistically valid sample. Cause: The institution's procedures and controls for determining and reporting withdrawal dates to NSLDS were not operating effectively to ensure that the actual effective date of withdrawal was reported accurately and that enrollment status changes were reported timely. Effect: Inaccurate or delayed reporting to NSLDS may result in incorrect enrollment information being maintained in federal systems, which could affect loan servicing activities, deferment eligibility, and the Department of Education's monitoring of student enrollment status. Questioned Costs: None reported Context: Controls did not operate properly for the University to timely and accurately report withdrawal information to NSLDS. Repeat Finding: No Recommendation: We recommend that the University evaluate its processes and controls to ensure withdrawal reporting information submitted to NSLDS is accurate and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.