Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)) Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 8 students who graduated or withdrew whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely to NSLDS. As a result, certain student status changes were not reported to NSLDS in a timely manner. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)) Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 8 students who graduated or withdrew whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely to NSLDS. As a result, certain student status changes were not reported to NSLDS in a timely manner. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires 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. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires 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. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)) Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 8 students who graduated or withdrew whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely to NSLDS. As a result, certain student status changes were not reported to NSLDS in a timely manner. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)) Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 8 students who graduated or withdrew whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely to NSLDS. As a result, certain student status changes were not reported to NSLDS in a timely manner. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires 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. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires 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. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.