Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Higher Education Emergency Relief Fund - Institutional - ALN 84.425F Federal Award Identification Number and Year - P425F201211 Pass - through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2021-001 Criteria - CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary at such time in such a manner as the secretary may require. ARP Act 2003 specifies that the same terms and conditions of CRRSAA 314 apply to HEERF III funds. While the acts do not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, pursuant to these requirements, the Department of Education required quarterly public reporting of student portion and institutional portion awards. Condition - The University did not timely file Institutional HEERF quarterly reporting for the quarter ended June 30, 2021 and the Institutional report for the quarter ended September 30, 2021 was inaccurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University did not timely file the institutional HEERF quarterly report and one instance where the University inaccurately completed the institutional quarterly report. Cause and Effect - The University did not track all due dates and reporting requirements in order to ensure that the quarterly public reporting was completed accurately and at the frequency required. Recommendation - We recommend the University put in place a process in order to ensure that all report due dates are tracked to ensure that all required reports are submit completely and accurately. Views of Responsible Officials and Planned Corrective Actions - When future reporting is required, the director of financial aid will review criteria against requirements and due dates and pass to the operation manager in financial aid and to the student accounting supervisor for a second review of content and due dates.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grant Program ALN 84.063, and Federal Supplemental Education Opportunity Grant Program No. 84.007 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes - 2021-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended)(34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. (34 CFR Section 668.22). Post withdrawal disbursements must be made from available grant funds before available loan funds (34 CFR 668.22(a)(6)). Post withdrawal disbursements of grant funds may be credited to the student?s account, without the student?s authorization, for current year outstanding charges for tuition, fees, and room and board (if contracted with the institution) on the student?s account, up to the amount of those outstanding charges. For current year outstanding charges other than tuition, fees, and room and board (if contracted with the institution), the institution must have the student?s authorization to credit the student?s account with grant funds. Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the withdrawal date required to be used based on federal regulations. The discrepancies in withdrawal dates resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not complete Title IV calculations based on federal regulations which resulted in untimely returns of Title IV funds and inaccurate return calculations. The University did not obtain student authorization prior to crediting student account for post withdrawal disbursement. Questioned Costs - $4,244 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were four errors that attributed to this finding: 1) Of the 21 students tested, there were 4 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $2,675 in questioned costs. 2) Of the 21 students tested there were 2 students identified where the University did not calculate the R2T4 correctly resulting in $1,569 in questioned costs. 3) Of the 21 students tested there were 5 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 4) Of the 21 students tested there was 1 student identified where the University did not obtain authorization from student prior to crediting account for post withdrawal disbursement. Cause and Effect - The University did not have a control in place to ensure all Title IV calculations, Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Recommendation - The University should implement controls to ensure all Title IV calculations, returns of Title IV refunds and post withdrawal disbursements are initiated timely and accurately. Views of Responsible Officials and Corrective Action Plan - One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes - 2021-004, 2020-004 and 2019-001 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were two errors identified that attributed to this finding. 1) Of the 40 students tested, there was 3 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University does not have adequate controls or processes in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of student campus and program level reporting. Views of Responsible Officials and Planned Corrective Actions - A new position was formed with the Title Assistant Registrar for Special Program and Compliance. This position was officially hired on January 11, 2022. They have gone through training for both NSC and NSLDS. They will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.
Assistance Listing Number, Federal Agency, and Program Name - Department of Education - Higher Education Emergency Relief Fund - Institutional - ALN 84.425F Federal Award Identification Number and Year - P425F201211 Pass - through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2021-001 Criteria - CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary at such time in such a manner as the secretary may require. ARP Act 2003 specifies that the same terms and conditions of CRRSAA 314 apply to HEERF III funds. While the acts do not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, pursuant to these requirements, the Department of Education required quarterly public reporting of student portion and institutional portion awards. Condition - The University did not timely file Institutional HEERF quarterly reporting for the quarter ended June 30, 2021 and the Institutional report for the quarter ended September 30, 2021 was inaccurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University did not timely file the institutional HEERF quarterly report and one instance where the University inaccurately completed the institutional quarterly report. Cause and Effect - The University did not track all due dates and reporting requirements in order to ensure that the quarterly public reporting was completed accurately and at the frequency required. Recommendation - We recommend the University put in place a process in order to ensure that all report due dates are tracked to ensure that all required reports are submit completely and accurately. Views of Responsible Officials and Planned Corrective Actions - When future reporting is required, the director of financial aid will review criteria against requirements and due dates and pass to the operation manager in financial aid and to the student accounting supervisor for a second review of content and due dates.