Audit 414868

FINDING 2026-001 Federal Program Information: Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not submit its next Roster File to NSLDS within 60 days. Condition: The University did not report students’ status changes accurately and within the required timeframe. Cause: Significant turnover of staff in the Registrar’s Office. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: For 14 of 40 campus-level records tested, the University did not timely report the student’s change in enrollment status. For 2 of 40 program-level records tested, the University did not accurately report all key data elements. Identification of Repeat Finding: This is a repeat of prior year finding 2025-001. Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner. Views of Responsible Officials: As of mid-June 2026, the Registrar’s Office is fully staffed. Multiple staff within the office have now been trained to complete the enrollment and degree reporting process for the National Student Loan Data System (NSLDS). One additional high-level information technology personnel has also been trained to complete the reporting processes. As part of this training, staff has participated in enrollment reporting webinars offered through the National Student Clearinghouse and in conjunction with NSLDS. This training will be an on-going process so that staff can stay abreast of any necessary reporting updates. Also, multiple staff members in the Registrar’s Office and several administrators are now included in the communications from the National Student Clearinghouse that provide reminders of due dates for enrollment and degree reporting to ensure that reporting happens in the appropriate time. To ensure that staff know the specific time periods for enrollment and degree reporting, information has been added to the Standard Operating Procedures (SOP) for “National Student Clearinghouse Reporting.” This document, which provides all instructions for enrollment and degree reporting, is housed in a shared file that is accessible to all staff in the Registrar’s Office and the high-level information technology personnel. This collection of personnel are those with access to complete the enrollment and degree reporting. Finally, we have added a report “NSC Error Report – Program Data” to check for enrollment program and status errors. This report will be run prior to every reporting submission to check for errors and to fix any errors prior to the file submission.

FINDING 2026-002 Federal Program Information: Federal Pell Grant Program (ALN 84.063) Criteria or Specific Requirement: C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: Certain instances in which Title IV funds drawn were held in excess of the allowable time frame were identified. Cause: Administrative oversight and insufficient internal control. Effect or Possible Effect: The University was not in compliance with the Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: None. Context: Two instances of excess cash that were not eliminated within the allowable time frame were identified for the Federal Pell Grant Program for the year ended May 31, 2026. Identification of Repeat Finding: This is a repeat of prior year finding 2025-003. Recommendation: We recommend that the University enhance its procedures and internal controls over cash management to ensure timely elimination of excess cash balances. Views of Responsible Officials: The University has implemented enhanced controls over Federal Pell Grant cash draws to ensure compliance with federal cash management requirements. The University will maintain an approximate $50,000 cushion between cumulative eligible financial aid disbursements and cumulative funds drawn through the G5 portal. Prior to each draw, cumulative financial aid awarded and recorded in the University’s general ledger will be reconciled to cumulative G5 draws to ensure funds requested do not exceed eligible disbursements. Additionally, the AVP for Business and Finance will review and approve each draw prior to submission to provide an additional level of oversight and ensure continued compliance with applicable federal cash management requirements.

FINDING 2026-003 Federal Program Information: Federal Pell Grant Program (Assistance Listing #84.063) Criteria or Specific Requirement: L. Reporting – Financial Reporting – Federal regulations (34 CFR 668.164(b)(3)(iii)) require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: Certain origination records contained inaccurate data. Cause: Administrative oversight and insufficient internal control. Effect or Possible Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 origination records tested, the University did not accurately report all key items. Identification of Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure accurate reporting of origination data. Views of Responsible Officials: Upon review of the data that was reported inaccurately, it was determined that updating this data point, the earliest enrollment date for the award year, via a systems integration was not the most reliable way to update the value. An internal system within the Financial Aid Management System (FAMS) will be used to populate this date going forward. The Financial Aid Office will add an additional quality check post origination as well to ensure accuracy.