Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar
Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts