Finding 2025-003 – Untimely Submission of the Single Audit Reporting Package to the Federal Audit Clearinghouse (FAC) (Material Weakness): Information on the federal program – Applicable to all federal programs subject to the Uniform Guidance audit requirements because the reporting package and data collection form submission requirements apply to the auditee’s Uniform Guidance reporting package. Criteria – Section 2 CFR §200.512(a) of the Uniform Guidance requires that “the reporting package and the Data Collection Form (DCF) must be electronically submitted by the auditee to the FAC” and that “submission must be completed within 30 calendar days after the auditee receives the auditor’s reports or 9 months after the end of the audit period, whichever is earlier.” Section 2 CFR §200.520 of the Uniform Guidance provides that one of the conditions necessary to qualify as a low-risk auditee is that “the prior 2 years’ audits must have been performed on an annual basis in accordance with the Uniform Guidance, including report submission to the FAC by the due date.” The Uniform Guidance also states that if an auditee expects a late submission, “the suggested way to do so is to contact the federal oversight or cognizant agency for the audit.” Condition – The auditee did not submit its audit reporting package and data collection form to the Federal Audit Clearinghouse within the time frame required by 2 CFR § 200.512(a). Specifically, the 2024 audit reporting package was submitted more than one year after the required due date, the 2023 reporting package was submitted 11 days late, and as of August 2026 the 2025 reporting package has not yet been submitted and is expected to be late. Cause – Based on discussions with management and auditor procedures performed, the auditee did not maintain an effective process to monitor Uniform Guidance reporting deadlines and ensure timely completion and submission of the reporting package and data collection form to the FAC. Effect – Failure to submit the reporting package and data collection form within the required deadline constitutes noncompliance with 2 CFR § 200.512(a). Repeated late submissions may affect the auditee’s ability to qualify as a low-risk auditee because timely FAC submission is one of the required conditions under Section 2 CFR § 200.520 of the Uniform Guidance. Questioned Costs – N/A Repeat Finding – No. However late FAC submissions occurred in prior reporting periods. Auditor’s Perspective – From the auditor’s perspective, repeated late submissions over multiple audit periods indicate a pattern of noncompliance with Uniform Guidance reporting requirements and suggest deficiencies in the auditee’s monitoring controls over regulatory reporting deadlines. The auditor also noted that the Uniform Guidance permits communication with the cognizant or oversight agency when a submission will be late; however, no evidence was provided that such communication occurred for all affected periods reviewed. Auditor's Recommendation – We recommend management implement formal procedures and monitoring controls to ensure completion and electronic submission of the reporting package and data collection form within the deadline established by 2 CFR § 200.512(a). We also recommend management designate responsible personnel to track Uniform Guidance due dates, maintain submission documentation, and communicate proactively with the cognizant or oversight agency if delays are anticipated. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-004 – U.S. Department of Education (ED) – Title III Program-Noncompliance With Cash Management, (Significant Deficiencies): Information on the federal program – Strengthening Historically Black Colleges and Universities (HBCU), ALN 84.031B, June 30,2025. Criteria – Under 2 CFR § 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred and must maintain supporting documentation available at the time of the drawdown demonstrating: 1. Actual, allowable expenditures existed at the time Federal funds were drawn; and 2. Records supporting the nature and timing of those expenditures were maintained and readily available for review. These requirements ensure that drawdowns reflect immediate cash needs supported by verifiable program expenditures. Condition – One (1) of eight (8) drawdowns tested for the Title III program was not based on actual expenditures incurred at the time the drawdown was requested. Audit testing determined that the University drew down $30,568 to fund a future payroll cycle more than fifteen (15) days before payroll costs were earned and incurred. As a result, Federal funds were requested in advance of immediate cash needs and were not supported by allowable program expenditures existing at the time of the drawdown. Cause – The condition occurred because the University did not have adequate procedures to ensure payroll expenditures included in drawdown requests had been incurred prior to requesting Federal funds. Management review controls did not detect that the drawdown included future payroll costs that had not yet been earned by employees. Effect – The University held Federal funds in advance of actual program expenditures, which is not consistent with the requirement that advance payments be limited to immediate cash needs. This condition increased the risk of excess Federal cash on hand, questioned costs, and noncompliance with Federal cash management requirements. Questioned Costs – $0. Repeat Finding – No. Auditor’s Perspective – From the auditors' perspective, the University's controls over cash management were not operating effectively to ensure that Federal drawdowns were based on allowable expenditures incurred and immediate cash needs. Specifically, the University drew down $30,568 for a future payroll cycle more than fifteen (15) days before the related payroll costs were earned and incurred. The lack of procedures to verify that expenditures had been incurred prior to requesting Federal funds resulted in noncompliance with Federal cash management requirements. Because this exception was identified in one of eight drawdowns tested, the deficiency increased the risk that Federal funds could be drawn and held in advance of program needs without timely detection. Auditor's Recommendation – We recommend that the University strengthen its cash management procedures to ensure that Federal drawdown requests are based solely on allowable expenditures that have been incurred as of the drawdown date. Prior to submitting a draw request, grant and finance personnel should reconcile requested amounts to supporting payroll records, general ledger expenditures, or other documentation evidencing incurred costs. In addition, management should perform and document a review of all drawdown requests to verify that requested funds are limited to the program's immediate cash needs and do not include future payroll or other anticipated expenditures. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-005 – U.S. Department of Education (ED) – Title III Program-Inadequate Control Over Payroll Cost Allocation and Time and Effort Reporting Requirements, (Material Weakness): Information on the federal program – Strengthening Historically Black Colleges and Universities (HBCU), ALN 84.031B, June 30,2025. Criteria – Compensation – Personnel Services Documentation Requirements: Under 2 CFR § 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, and such records must: • Be supported by a system of internal controls providing reasonable assurance that the charges are accurate, allowable, and properly allocated; • Reflect 100% of the employee’s compensated activities, both Federal and non-Federal; • Be incorporated into the official records of the non-Federal entity; and • Be completed and documented in a timely and consistent manner. For Title III programs, personnel costs must be supported by complete and accurate documentation demonstrating the portion of time dedicated to allowable Title III activities. Condition – During our testing of payroll expenditures charged to the Title III program, we noted exceptions in eight (8) of nine (9) payroll transactions selected for testing, which is an 89% error rate. Specifically: • For two (2) of nine (9) transactions tested, salary expenses charged to the Title III grant did not agree with the grant allocation percentages authorized in employee contracts, personnel action forms, or other approved Human Resources documentation. • For six (6) of nine (9) transactions tested, salary expenses charged to the Title III grant did not agree with the employees' documented distribution of actual time and effort as reflected on certified time and effort reports. As a result, payroll costs charged to the Title III programs were not consistently supported by approved personnel documentation or by records reflecting actual work performed on the program. Cause – Management did not establish or effectively implement procedures to ensure salary costs charged to the Title III program were consistently supported by approved personnel allocation documentation and reconciled to certified time and effort reports reflecting actual work performed. In addition, supervisory review controls designed to verify the accuracy of payroll allocations before reimbursement requests and financial reporting were not operating effectively. Effect – Without procedures to ensure payroll allocations are supported by approved personnel records and reconciled to certified time and effort documentation; there is an increased risk that payroll costs charged to the Title III program may be unallowable, inaccurately allocated, or not supported in accordance with Federal requirements. Questioned Costs – $4,522 Repeat Finding – No Auditor’s Perspective – The testing results disclosed a systemic breakdown in controls over payroll allocations charged to the Title III program, as exceptions were identified in 89% of the transactions tested. The pervasive nature of the exceptions indicates that management's controls were not sufficient to provide reasonable assurance that payroll costs charged to the Federal award were accurate, allowable, and properly supported. Consequently, there is a reasonable possibility that material noncompliance with Federal requirements could occur and not be detected in a timely manner. Auditor’s Recommendation – We recommend that management strengthen internal controls over payroll allocations charged to federal awards by: 1. Ensuring employee contracts, personnel action forms, and approved grant allocation schedules accurately reflect the intended distribution of salary costs among funding sources. 2. Requiring periodic reconciliations between payroll charges recorded in the general ledger, approved salary allocation documentation, and certified time and effort reports. 3. Implementing a documented supervisory review process to verify that payroll expenditures charged to the Title III program are supported by records that accurately reflect actual work performed before costs are charged to the grant. 4. Providing training to personnel responsible for grant accounting and payroll administration regarding the requirements of 2 CFR §200.430 related to compensation and time and effort reporting. Views of Responsible Officials - Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-006 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Reconcile Title IV Programs (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.24 (a), institutions must maintain records necessary to demonstrate compliance with the requirements of Title IV of the Higher Education Act (HEA) programs, including records that support the accuracy of disbursements and fiscal transactions. Per the Federal Student Aid Handbook, Volume 4 – Processing Aid and Managing Funds, institutions are required to reconcile internal disbursement and expenditure records with the Business Office, general ledger, and the Department of Education’s systems (COD, G5, etc.) on a monthly basis for all Title IV programs. Additionally, for Federal Direct Loans specifically, per 34 CFR § 685.300(b)(5), institutions must reconcile the institution’s Federal Direct Loan records with the Department’s records at least monthly and resolve any discrepancies. Condition – The University did not perform required reconciliations between the Office of Financial Aid and the Business Office for the following Title IV programs during the audit period: • Federal Pell Grant Program • Federal Direct Student Loans • Federal Supplemental Educational Opportunity Grant (FSEOG) • Federal Work-Study (FWS) Program As a result, disbursement records maintained by the Office of Financial Aid did not reconcile to the general ledger or COD for any of the programs reviewed. No documentation of monthly or year-end reconciliations was provided for audit examination. Cause – The lack of reconciliation appears to have resulted from insufficient coordination and reconciliation timeliness between the Office of Financial Aid and the Business Office Effect – Failure to reconcile may impact the University’s administrative capability under 34 CFR § 668.16, exposing the University to regulatory review, questioned costs, and potential repayment liability. There is also an increased risk of overpayments or underpayments of federal aid and misstatements in the Schedule of Expenditures of Federal Awards (SEFA) and general ledger. Questioned Costs – $0 Repeat Finding – Yes Auditor’s Perspective – Reconciliation is a foundational internal control for Title IV program administration. The failure to reconcile across all four major programs indicates a systemic, not isolated, weakness in financial aid and accounting oversight. Auditor’s Recommendation – The University should implement monthly reconciliations, strengthen cross-department coordination, and perform year-end reconciliation prior to FISAP submission. Implementation of these measures will help ensure compliance with federal regulations, reduce financial reporting risk, and reinforce the University’s administrative capability. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-007 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Unreconciled Expenditures Reported on the FISAP (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.24 (a), institutions must maintain records necessary to demonstrate compliance with the requirements of Title IV programs, including records that support the accuracy of disbursements and fiscal transactions. Per the Federal Student Aid Handbook, Volume 4 – Processing Aid and Managing Funds, institutions are required to reconcile internal disbursement and expenditure records with the Business Office, general ledger, and the Department of Education’s systems on a monthly basis for all Title IV programs prior to completing year-end federal reporting including the FISAP. Condition – The Office of Financial Aid submitted unreconciled expenditure amounts in the institution’s Fiscal Operations Report and Application to Participate (FISAP). At the time of audit, the reported FISAP totals did not reconcile to the applicable federal systems (COD) or to the Student Financial Aid (SFA) reconciliation report. No documentation was provided to demonstrate that final reconciliations were completed prior to submission of the FISAP. Cause – The lack of reconciliation appears to have resulted from insufficient coordination and reconciliation timeliness between the Office of Financial Aid and the Business Office Effect – Failure to reconcile may impact the institution’s administrative capability under 34 CFR § 668.16, exposing the University to regulatory review, questioned costs, and potential repayment liability. The accuracy and reliability of the FISAP submission cannot be assured. Questioned Costs – $0 Repeat Finding - Yes Auditor’s Perspective – The FISAP serves as a primary financial reporting tool used by the Department of Education to determine campus-based program funding and institutional compliance. Submitting unreconciled figures undermines the integrity of federal reporting and represents a systemic breakdown in financial oversight rather than an isolated reporting error. Auditor’s Perspective – (continued) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: a. Federal Pell Grant Program b. Federal Work Study (FWS) Program c. Federal Supplemental Educational Opportunity Grant (FSEOG) Auditor’s Recommendation – The University should implement monthly reconciliations, strengthen cross-department coordination, perform year-end reconciliation prior to FISAP submission. Implementation of these measures will strengthen financial accountability, improve federal reporting accuracy, and reduce the likelihood of future findings. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-008 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Untimely Return of Title IV Funds and Insufficient Documentation (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.22 (j), (1) an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Additionally, 34 CFR § 668.24 requires institutions participating in the Title IV programs to establish and maintain records necessary to demonstrate compliance with Title IV program requirements. Such records must be sufficient to support the institution's determination, calculation, and timely return of Title IV funds for students who withdraw. Condition – During testing of the University's compliance with Return of Title IV Funds (R2T4) requirements, we noted exceptions for four (4) students selected for testing. For three (3) students, the University did not return unearned Title IV funds within the required 45-day timeframe. The returns were made after the regulatory deadline. For one (1) additional student, the University did not provide all documentation requested to support the student's R2T4 determination and calculation. As a result, we were unable to determine whether the calculation was accurate, whether the appropriate amount of Title IV funds was returned, or whether any required return was completed within the required timeframe. Cause – The exceptions appear to have resulted from insufficient monitoring and internal controls over the R2T4 process, including procedures to ensure that required returns are identified and processed within the 45-day timeframe and that complete supporting documentation is maintained and readily available for review. Effect – Failure to return unearned Title IV funds within the required timeframe results in noncompliance with federal R2T4 requirements and may expose the University to repayment liabilities and additional regulatory oversight. Effect – (continued) Additionally, failure to maintain sufficient supporting documentation prevents the University from demonstrating compliance with federal requirements and increases the risk that R2T4 calculations, return amounts, and return dates may be inaccurate or unsupported. Questioned Costs – $0 Repeat Finding – Yes Auditor’s Perspective – The exceptions identified demonstrate weaknesses in the University's controls over the timeliness and documentation of the R2T4 process. Three students had confirmed untimely returns, while sufficient documentation was not provided for a fourth student to allow the auditors to determine compliance. Although the documentation exception does not, by itself, establish that an untimely or incorrect return occurred, the absence of sufficient documentation limits the University's ability to demonstrate compliance with federal requirements. Auditor’s Recommendation – The University should strengthen its procedures and internal controls over the Return of Title IV Funds process to ensure that all required R2T4 calculations are completed timely and that unearned Title IV funds are returned within 45 days of the University's determination that a student withdrew. The University should also establish procedures to ensure that complete supporting documentation is maintained for each R2T4 calculation, including the withdrawal determination, withdrawal date, calculation, institutional charges, aid disbursed or that could have been disbursed, return amounts, and evidence supporting the date funds were returned. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-009 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Untimely Release of Title IV Credit Balances (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.164 (h)(1)-(2), institutions must pay a Title IV credit balance to the student (or parent for a PLUS Loan) no later than 14 calendar days after the balance occurs Condition – During testing of student account activity, we identified that five (5) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. Cause – The delays appear to have resulted from insufficient monitoring of aged credit balances on student accounts. Effect – Holding Title IV funds beyond 14 days impacts the University’s administrative capability under 34 CFR § 668.16, exposing the University to regulatory findings and required corrective action. Questioned Costs - $0 Repeat Finding – Yes Auditor’s Perspective – Timely release of Title IV credit balances is one of the Department of Education’s most frequently tested compliance areas. A failure rate of 8.3% (5 out of 60 students) suggests a weakness in the University’s processes. Auditor’s Recommendation – The University should implement weekly monitoring of credit balances, improve coordination between departments, and establish system alerts or automated processes. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-010 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Document High School Completion for Title IV Eligibility (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Under Higher Education Act (HEA) § 484(d), a student must possess a high school diploma or its recognized equivalent, or meet an allowable alternative eligibility standard, to receive Title IV federal student aid. Per 34 CFR § 668.32(e), a student is eligible to receive Title IV funds only if the institution has documentation showing that the student has a high school diploma or recognized equivalent, or has completed homeschooling, or meets the requirements for Ability-to-Benefit (ATB). Condition – During testing of student eligibility, we noted that one (1) out of sixty (60) sampled students did not have documentation of high school completion or its recognized equivalent (e.g., high school transcript, diploma, or GED certificate) in their student files. Despite the absence of proof of high school completion, the student was enrolled and awarded Title IV federal student aid. Cause – The exception appears to have resulted from failure to collect or retain required documentation at the time of admission or prior to awarding aid and lack of a systematic verification checkpoint to confirm high school completion before packaging Title IV awards. Effect – Noncompliance may impact the University’s administrative capability under 34 CFR § 668.16, exposing the University to inaccurate reporting and potential repayment liability. Questioned Costs - $12,895 Auditor’s Perspective – Of the 60 students selected for testing, 1 student, or 1.67% of the sample, did not have sufficient documentation to demonstrate completion of high school or its recognized equivalent. The absence of required documentation prevents the institution from demonstrating that the student's Title IV eligibility was adequately supported prior to the disbursement of federal student aid. Repeat Finding – Yes Auditor’s Recommendation – The University should implement a mandatory eligibility verification process and strengthen document collection and retention controls. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-011 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Obtain Required Verification Documentation Prior to Disbursing Title IV Aid (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.53(a)(3) and 34 CFR § 668.56, when a student is selected for verification, the institution must collect and review the required verification documentation before disbursing Title IV funds, unless the student qualifies for a permitted interim disbursement or other regulatory exception. Additionally, under 34 CFR § 668.16(f), the institution must develop and apply an adequate system to identify and resolve discrepancies in information that would affect a student’s Title IV eligibility. Condition – During testing of sixty (60) students, seven (7) students were identified as having been selected for verification. Of the seven (7) students subject to verification, two (2) students did not have the required verification documentation in the student file; however, Title IV funds were disbursed on the students’ behalf. As a result, the University disbursed Title IV funds without documentation demonstrating that the students’ eligibility had been verified in accordance with federal requirements. Cause – The exceptions appear to have occurred due to breakdowns in the verification tracking process and insufficient review procedures to prevent packaging and disbursement prior to completing verification. Effect – As a result, the University awarded and disbursed Title IV funds to students whose eligibility was not properly verified. This creates a risk of improper payment and may result in questioned costs for the Title IV funds disbursed to students. Questioned Costs – $5,546 Repeat Finding – Yes Auditor’s Perspective – Verification is a key Title IV eligibility control designed to ensure that federal aid is awarded based on accurate and supported student information. In this instance, two (2) out of seven (7) students selected for verification (28.57%), or two (2) out of sixty (60) students tested overall (3.33%), did not have the required documentation on file prior to disbursement. The absence of the required documentation prevents the University from demonstrating that verification was properly completed and that the students’ eligibility for Title IV funds was adequately supported prior to disbursement. The 28.57% exception rate among students subject to verification indicates a weakness in the University’s controls over the verification process and its maintenance of documentation necessary to substantiate compliance with Title IV requirements. Auditor’s Recommendation – The University should implement a verification checklist and tracking system, strengthen internal controls, and perform periodic file audits. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-012 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Early Disbursement of Pell Grant Funds (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.164 (b)(1), institutions may disburse Title IV funds no earlier than 10 days before the first day of classes of a payment period. Per 34 CFR § 668.164 (a), a disbursement occurs when the institution credits a student’s account with title IV funds or pays the student directly. Posting Pell funds more than 10 days before the start date violates federal disbursement timing rules. Condition – During our review of Pell Grant disbursements, we identified that the University drew down and credited Pell Grant funds to student accounts more than 10 days prior to the start of the payment period. Specifically, twenty-nine (29) out of sixty (60) students tested had Pell funds credited 11 days before the payment period start date. As a result, Title IV funds were posted to student ledgers before students became eligible to receive the disbursements under federal disbursement timing requirements. Cause – The exception appears to have resulted from incorrect or premature disbursement dates, lack of coordination between Financial Aid and the Business Office regarding the approved disbursement calendar and insufficient controls. Effect – Pell funds being disbursed earlier than allowed may impact the University’s administrative capability under 34 CFR § 668.16, increasing risk of funds being provided to students who may never begin attendance, improper cash management and potential liabilities or repayment of funds. Questioned Costs - $0 Repeat Finding - Yes Auditor’s Perspective – A failure rate of 29 out of 60 students (48.3%) represents a significant and systemic breakdown in the University’s Title IV disbursement controls. This is not an isolated occurrence as it indicates that nearly half of all students tested received Pell disbursements earlier than permitted. Such a high exception rate suggests that the University’s disbursement schedule, system configuration, and internal oversight processes are not functioning as required, and that the issue is likely affecting all Title IV disbursements, not just the students sampled. Auditor’s Recommendation – The University should review and correct disbursement calendars, strengthen system controls, and monitor disbursements regularly. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-013 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Inaccurate Enrollment Reporting to the National Student Loan Data System (NSLDS) (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 685.309(b) and 34 CFR § 690.83, institutions are required to report accurate and timely student enrollment information to National Student Loan Data System (NSLDS). The enrollment information must reflect each student’s current enrollment status and must be submitted within 60 days of any change in student status or in accordance with the schedule established by the U.S. Department of Education. Condition – During testing of enrollment reporting, we noted that one (1) out of six (6) sampled students had inaccurate enrollment information reported to the National Student Loan Data System (NSLDS). Enrollment status for the student was not updated correctly or timely in accordance with federal reporting requirements. Cause – It appears that the exception occurred because the University did not have adequate monitoring procedures in place to ensure compliance for updating and reconciling enrollment changes between the registrar’s system and the NSLDS submission system. Effect - Failure to accurately and timely report student enrollment statuses can result in incorrect loan deferment or grace period tracking for affected borrowers, potential early loan repayment obligations for students who are no longer enrolled, and findings in federal program reviews or compliance audits. There is also an increased risk of administrative capability concerns under 34 CFR § 668.16. Questioned Costs – $0 Repeat Finding – Yes Auditor’s Perspective – Accurate enrollment reporting is critical because it directly affects borrowers’ repayment obligations and loan servicing timelines. Although only one (1) of six (6) students tested had an inaccurate record, this represents a material process weakness due to the high sensitivity and federal reliance on accurate enrollment data. The Department of Education treats even single enrollment reporting failures as significant because they disproportionately impact borrower rights and federal loan servicing. Auditor’s Recommendation –The University should establish a formal reconciliation process to verify all student status changes are reported timely as well as conduct periodic reviews to ensure the accuracy of student status data. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-014 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Inaccurate Recipient Counts Reported on the FISAP (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.14 (b)(19) – Program Participation Agreement (PPA), institutions must accurately report to the Secretary information that the Secretary requires for participation in any Title IV, HEA program. Per 34 CFR § 690.83 (a), institutions must report annually to the Secretary the total number of students receiving Pell Grants and the distribution of those recipients by income category and ensure the report is complete and accurate. Inaccurate reporting violates federal reporting requirements and the institution’s Program Participation Agreement (PPA). Condition – During testing of the Fiscal Operations Report and Application to Participate (FISAP), we compared the number of recipients reported in selected income categories to the income information contained in the ISIRs reviewed. We found that the counts reported on the FISAP did not match the ISIR data, resulting in inaccurate reporting of Pell Grant recipients across certain income ranges. Cause – The inaccuracies appear to have resulted from failure to reconcile ISIR income information to the summary totals reported on the FISAP, use of incorrect or incomplete datasets when preparing recipient counts, and insufficient supervisory review over the FISAP reporting process. Effect - The Department of Education may receive incorrect statistical and demographic reporting used for policymaking and funding formulas, the institution is not in compliance with federal reporting requirements and its Program Participation Agreement, and there is also an increased risk of administrative capability concerns under 34 CFR § 668.16. Questioned Costs - $0 Repeat Finding - Yes Auditor’s Perspective – Accurate reporting of Pell Grant recipients by income category is essential because ED uses these data for national policy purposes, campus-based funding allocations, and program monitoring. Discrepancies between FISAP reported totals and ISIR data indicate a systemic reporting weakness, rather than a clerical oversight, and demonstrate the need for stronger data validation and reconciliation procedures. Auditor’s Recommendation - The University should strengthen review and approval controls and improve data validation processes by ensuring that datasets used for FISAP preparation are complete, consistent, and aligned with financial aid records. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-015 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs Title IV Aid Awarded Without Support for Appropriate Dependency Status (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – Per 34 CFR § 668.32, a student must meet applicable eligibility requirements to receive Title IV, HEA program assistance. The institution is responsible for ensuring that information used to determine a student's eligibility for Title IV assistance is complete, accurate, and appropriately supported. Additionally, 34 CFR § 668.24 requires institutions participating in Title IV programs to establish and maintain records necessary to demonstrate compliance with Title IV requirements, including documentation sufficient to support a student's eligibility for federal student aid. A student's dependency status is a component of the FAFSA eligibility determination and affects the information required to calculate the student's eligibility for Title IV assistance. Institutions must ensure that unresolved, incomplete, or conflicting information affecting a student's eligibility is appropriately reviewed and resolved before Title IV aid is disbursed. Condition – During testing of student eligibility, we noted that the ISIR maintained for one student did not reflect an appropriate dependency model and instead reflected a dependency model of “X.” The University disbursed $3,698 in Title IV aid to the student. Documentation was not provided to demonstrate that the student's appropriate dependency status had been established and supported prior to the disbursement of Title IV funds. Cause – The exception appears to have resulted from inadequate review of ISIR information and insufficient controls to ensure that a student's dependency status and applicable eligibility information are appropriately resolved and supported prior to the awarding and disbursement of Title IV aid. Effect – Failure to establish and document the student's appropriate dependency status prior to awarding Title IV aid increases the risk that federal student aid may be awarded based on incomplete or unsupported eligibility information. As a result, the University was unable to demonstrate that the $3,698 in Title IV assistance awarded to the student was properly supported. Questioned Costs - $3,698 Repeat Finding – No Auditor’s Perspective – Of the 60 students selected for testing, one (1) student, or 1.67% of the sample, had an ISIR that did not reflect an appropriate dependency model and for whom sufficient documentation was not provided to demonstrate that the student's dependency status had been appropriately established prior to the awarding/disbursement of Title IV aid. While the exception appears isolated based on the sample tested, appropriate determination and documentation of dependency status is an important component of establishing a student's eligibility and ensuring that Title IV aid is awarded based on accurate and complete FAFSA/ISIR information. Auditor’s Recommendation - The University should strengthen its procedures for reviewing ISIR transactions prior to awarding and disbursing Title IV aid. Financial Aid personnel should verify that each student's dependency status is appropriately reflected on the applicable ISIR and that any conflicting, incomplete, or unresolved dependency information is reviewed and resolved before Title IV eligibility is finalized. The University should also review the identified student's record to determine the appropriate dependency status, obtain and retain supporting documentation, submit any required corrections, and recalculate the student's Title IV eligibility, as applicable. Any Title IV funds determined to have been improperly disbursed should be returned in accordance with applicable federal requirements. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-016 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Direct Unsubsidized Loan Aggregate Limit Exceeded (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – In accordance with 34 CFR § 685.203, a student's eligibility for Federal Direct Subsidized and Unsubsidized Loans is subject to applicable annual and aggregate loan limits. An institution may not originate or disburse a Direct Loan that would cause a student to exceed the applicable aggregate loan limit. Additionally, 34 CFR § 668.24 requires institutions participating in Title IV programs to maintain records necessary to demonstrate compliance with federal student aid requirements and to support the eligibility and amounts of Title IV assistance awarded and disbursed to students. Institutions are responsible for reviewing available student loan history and ensuring that a student's remaining eligibility is sufficient before originating and disbursing additional Direct Loan funds. Condition – During testing of Federal Direct Loan eligibility, we noted that one student received Federal Direct Unsubsidized Loan funds that caused the student to exceed the applicable aggregate loan limit by $579. The University did not identify and resolve the student's aggregate loan limit prior to disbursing the additional loan funds. Cause – The exception appears to have resulted from insufficient review and monitoring of the student's cumulative Federal Direct Loan borrowing prior to the disbursement of additional Unsubsidized Direct Loan funds. Effect – Failure to adequately monitor aggregate loan limits resulted in the student receiving $579 in Federal Direct Unsubsidized Loan funds in excess of the applicable aggregate limit. This resulted in noncompliance with federal Direct Loan requirements and may require corrective action to restore the student's eligibility and resolve the excess loan amount in accordance with applicable federal requirements. Questioned Costs – $579 Repeat Finding – Yes Perspective – Of the 60 students selected for testing, one (1) student, or 1.67% of the sample, received Federal Direct Unsubsidized Loan funds in excess of the student's applicable aggregate loan limit. The amount exceeding the aggregate limit was $579. While the exception appears isolated based on the sample tested, monitoring annual and aggregate loan limits is an important Title IV eligibility control designed to prevent students from receiving Direct Loan funds in excess of federally established borrowing limits. Auditor's Recommendation – The University should strengthen its procedures for reviewing students' Federal Direct Loan history prior to originating and disbursing additional loan funds. Financial Aid personnel should verify each student's cumulative borrowing, applicable aggregate loan limit, and remaining loan eligibility using current NSLDS information and other applicable institutional records. The University should also review the identified student's account and take appropriate corrective action to resolve the $579 excess loan amount in accordance with federal requirements. Management should implement or strengthen supervisory review and system controls designed to identify students who are approaching or have reached applicable aggregate loan limits before additional Direct Loan funds are disbursed. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates. 42
Finding 2025-017 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Pell Grant Under Awarded (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – In accordance with 34 CFR § 690.62, institutions participating in the Federal Pell Grant Program are responsible for determining and disbursing the appropriate Federal Pell Grant amount for each eligible student based on the student's applicable Scheduled Federal Pell Grant Award and enrollment intensity for the payment period. Additionally, 34 CFR § 668.24 requires institutions to establish and maintain records sufficient to demonstrate the proper administration of Title IV programs and to support the eligibility and amounts of Title IV assistance awarded and disbursed. Federal Pell Grant payments must be calculated in accordance with applicable Federal Pell Grant payment requirements, including the student's enrollment intensity and eligibility for each payment period. Eligible students may also receive additional Federal Pell Grant funds under the Year- Round Pell provisions, subject to applicable eligibility requirements and the statutory maximum of 150 percent of the student's Scheduled Federal Pell Grant Award for the award year. Condition – During testing of Federal Pell Grant eligibility and disbursements, we noted that one student was not awarded the full amount of Federal Pell Grant funds for which the student was eligible during the 2024–2025 award year. The student was enrolled during the Fall, Spring, and summer payment periods and was eligible for Federal Pell Grant funds based on the student's applicable Pell Grant eligibility and enrollment intensity. However, the institution disbursed less Federal Pell Grant assistance than the amount for which the student was eligible. Additionally, the student's institutional account reflected $4,622, while the COD Pell SAS Report reflected $6,019, resulting in an unreconciled difference of $1,397. Cause – The exception appears to have resulted from insufficient controls over the calculation, awarding, and reconciliation of Federal Pell Grant funds, including procedures to ensure that Pell eligibility is appropriately calculated for each payment period and that the University’s disbursement records agree with amounts reported to COD. Effect – Failure to accurately calculate and disburse Federal Pell Grant eligibility resulted in the student receiving less Federal Pell Grant assistance than the amount for which the student was eligible. Additionally, the unreconciled difference between the institution's records and COD increases the risk that Federal Pell Grant disbursements are not accurately recorded, reported, and reconciled. Questioned Costs – $0 Repeat Finding – No Auditor’s Perspective – Of the 60 students selected for testing, one (1) student, or 1.67% of the sample, was identified as having received less Federal Pell Grant assistance than the amount for which the student was eligible. While the exception appears isolated based on the sample tested, accurate calculation and disbursement of Federal Pell Grant eligibility is a fundamental Title IV control. The exception also identified a discrepancy between the institution's student account records and amounts reported to COD, indicating a need for strengthened controls over Pell Grant calculation and reconciliation. Auditor's Recommendation – The University should review the identified student's Federal Pell Grant eligibility for each applicable payment period and determine the exact amount of the under award. The University should make any additional disbursement for which the student remains eligible and take any necessary corrective action in COD in accordance with applicable Federal Student Aid requirements. The University should also strengthen its procedures for calculating Federal Pell Grant awards, including Year-Round Pell, and implement controls to ensure that enrollment intensity, Scheduled Award amounts, and remaining Pell eligibility are reviewed for each applicable payment period. Additionally, the University should reconcile Pell Grant disbursements recorded in the student information system and general ledger to amounts accepted by COD and investigate and resolve the $1,397 discrepancy identified for this student. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-018 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Document Required Direct Loan Entrance and Exit Counseling (Significant Deficiency): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – In accordance with 34 CFR § 685.304(a), an institution must ensure that entrance counseling is provided to first-time student borrowers of Federal Direct Subsidized and Unsubsidized Loans prior to the borrower receiving the first disbursement of a Direct Loan, as applicable. Additionally, 34 CFR § 685.304(b) requires an institution to provide exit counseling to Direct Loan borrowers shortly before the student ceases at least half-time enrollment, including when the student graduates or withdraws. When a student leaves without the institution's prior knowledge or fails to complete counseling, the institution must provide the required exit counseling information in accordance with federal requirements. Further, 34 CFR § 668.24 requires institutions to establish and maintain records sufficient to demonstrate compliance with Title IV program requirements. Condition – During testing of Federal Direct Loan requirements, we noted that the University was unable to provide documentation demonstrating completion of required loan counseling for four students, as follows: • Two (2) students did not have documentation supporting completion of required entrance counseling; and • Two (2) students did not have documentation supporting completion or provision of required exit counseling. As a result, the University was unable to demonstrate compliance with applicable Federal Direct Loan counseling requirements for the students identified. Cause – The exceptions appear to have resulted from insufficient procedures for monitoring completion of required Direct Loan entrance and exit counseling and maintaining documentation supporting compliance with federal counseling requirements. Effect – Failure to ensure and document required entrance and exit counseling results in noncompliance with Federal Direct Loan program requirements and increases the risk that student borrowers may not receive required information regarding their rights and responsibilities, repayment obligations, loan terms, and available repayment options. Questioned Costs – $0 Repeat Finding – No Auditor’s Perspective – Of the 60 students selected for testing, four (4) students, or 6.67% of the sample, did not have documentation supporting compliance with applicable Direct Loan counseling requirements. Specifically, two students lacked documentation of required entrance counseling, and two students lacked documentation supporting required exit counseling. The exceptions indicate a weakness in the University's procedures for monitoring and documenting compliance with Federal Direct Loan counseling requirements. However, based on the sample tested, the exceptions alone do not necessarily indicate a pervasive or systemic failure of the University's Direct Loan counseling process. Auditor's Recommendation – The University should strengthen its procedures for monitoring and documenting Federal Direct Loan entrance and exit counseling requirements. Financial Aid personnel should establish procedures to verify completion of required entrance counseling prior to applicable loan disbursements and to ensure that exit counseling is completed or that required counseling materials are provided within applicable federal timeframes when borrowers graduate, withdraw, or cease at least half-time enrollment. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.
Finding 2025-019 – U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Failure to Provide Annual Fire and Safety Notification (Material Weakness): Information on the federal program – Federal Direct Student Loans, ALN 84.268, June 30, 2025; Federal Pell Grant Program, ALN 84.063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, ALN 84.007, June 30, 2025; Federal Work-Study Program, ALN 84.033, June 30, 2025. Criteria – In accordance with 34 CFR § 668.41(e), an institution must annually distribute to all enrolled students and current employees the required annual security report containing the campus security policies and crime statistics required under federal law. The institution must also provide notice to prospective students and prospective employees regarding the availability of the report. Additionally, institutions that maintain on-campus student housing facilities are subject to the fire safety reporting requirements under 34 CFR § 668.41(e) and 668.49. Such institutions must annually distribute the Annual Fire Safety Report, which includes required fire statistics and information regarding fire safety systems, policies, procedures, evacuation practices, and fire safety education and training. Institutions may combine the Annual Security Report and Annual Fire Safety Report into a single document, provided the applicable federal requirements are met and the required information is distributed to the appropriate students and employees. Condition – During testing of the University's compliance with annual campus safety and fire safety reporting requirements, the institution did not provide documentation demonstrating that the required annual notification was distributed to enrolled students and current employees during the audit period. As a result, we were unable to verify that students and employees were appropriately notified of the availability of the required annual security and, as applicable, fire safety information in accordance with federal requirements. Cause – The condition appears to have resulted from insufficient procedures for ensuring that the required annual notification is distributed to students and employees and that documentation supporting the distribution is maintained and readily available for review. Effect – Failure to distribute and maintain documentation supporting the required annual notification may result in noncompliance with federal campus security and fire safety reporting requirements. Additionally, students and employees may not receive timely access to required information regarding campus crime statistics, security policies, emergency procedures, fire safety statistics, and fire safety practices. Questioned Costs – $0 Repeat Finding – No Perspective – The annual notification requirement is an important component of the University's responsibility to provide students and employees with timely access to federally required campus safety and fire safety information. The absence of documentation demonstrating distribution of the required notification prevents the University from demonstrating compliance with applicable annual disclosure requirements. Auditor's Recommendation – The University should establish and implement procedures to ensure that the required annual notification is distributed to all enrolled students and current employees within the federally required timeframe. The University should also maintain documentation supporting the date, method, and population to which the notification was distributed. Management should assign responsibility for preparing, reviewing, distributing, and retaining evidence of the annual notification and implement a supervisory review process to ensure that all applicable campus security and fire safety reporting requirements are completed timely. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.