Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required. Additionally, during an examination of Direct Loan disbursement records, an instance in which loan proceeds were disbursed prior to having obtained a legally enforceable promissory note was identified. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 1 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Direct Loan disbursement records tested, the University disbursed loan proceeds without having obtained a legally enforceable promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD. Views of Responsible Officials: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student?s Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids ?Ready to Disburse? statuses.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported to NSLDS. Program Level: Significant data elements were inaccurately reported for certain students. Additionally, error records were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not report the student?s graduated status to NSLDS. For 2 of 25 program level records tested, the University did not accurately report the student?s enrollment status to NSLDS. For 3 of 25 program level records tested, the University did not accurately report the student?s enrollment effective date to NSLDS. Errors identified in two Error/Acknowledgment files received during fiscal year 2022 were not corrected within 10 days. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure students? enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required. Additionally, during an examination of Direct Loan disbursement records, an instance in which loan proceeds were disbursed prior to having obtained a legally enforceable promissory note was identified. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 1 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Direct Loan disbursement records tested, the University disbursed loan proceeds without having obtained a legally enforceable promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD. Views of Responsible Officials: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student?s Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids ?Ready to Disburse? statuses.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported to NSLDS. Program Level: Significant data elements were inaccurately reported for certain students. Additionally, error records were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not report the student?s graduated status to NSLDS. For 2 of 25 program level records tested, the University did not accurately report the student?s enrollment status to NSLDS. For 3 of 25 program level records tested, the University did not accurately report the student?s enrollment effective date to NSLDS. Errors identified in two Error/Acknowledgment files received during fiscal year 2022 were not corrected within 10 days. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure students? enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: HEERF Supplemental Assistance for Institutions of Higher Education (SAIHE) Program (ALN 84.425S) Criteria or Specific Requirement: Institutions must receive affirmative written consent before providing an emergency financial aid grant to a student?s account. Condition: The University credited emergency financial aid grants to students? accounts without getting affirmative written consent. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with federal guidelines over making emergency financial aid grants to students. Questioned Costs: None. Context: The University was allocated $991,895 of HEERF SAIHE funds, under Absolute Priority 6, which limited the use of these funds to making financial aid grants to students. The University appropriately used the funds to award additional financial aid grants; however, students did not have discretion about how to receive these grants. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over awarding and disbursing financial aid to ensure adherence to all federal guidelines. Views of Responsible Officials: The University applied for and received the SAIHE grant to assist our students. There was no definitive guidance on handling of the funds for the students. As a result, we posted the grant proceeds to the students? accounts.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required. Additionally, during an examination of Direct Loan disbursement records, an instance in which loan proceeds were disbursed prior to having obtained a legally enforceable promissory note was identified. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 1 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Direct Loan disbursement records tested, the University disbursed loan proceeds without having obtained a legally enforceable promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD. Views of Responsible Officials: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student?s Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids ?Ready to Disburse? statuses.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported to NSLDS. Program Level: Significant data elements were inaccurately reported for certain students. Additionally, error records were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not report the student?s graduated status to NSLDS. For 2 of 25 program level records tested, the University did not accurately report the student?s enrollment status to NSLDS. For 3 of 25 program level records tested, the University did not accurately report the student?s enrollment effective date to NSLDS. Errors identified in two Error/Acknowledgment files received during fiscal year 2022 were not corrected within 10 days. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure students? enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required. Additionally, during an examination of Direct Loan disbursement records, an instance in which loan proceeds were disbursed prior to having obtained a legally enforceable promissory note was identified. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 1 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Direct Loan disbursement records tested, the University disbursed loan proceeds without having obtained a legally enforceable promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD. Views of Responsible Officials: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student?s Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids ?Ready to Disburse? statuses.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported to NSLDS. Program Level: Significant data elements were inaccurately reported for certain students. Additionally, error records were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not report the student?s graduated status to NSLDS. For 2 of 25 program level records tested, the University did not accurately report the student?s enrollment status to NSLDS. For 3 of 25 program level records tested, the University did not accurately report the student?s enrollment effective date to NSLDS. Errors identified in two Error/Acknowledgment files received during fiscal year 2022 were not corrected within 10 days. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure students? enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies.
Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.
Federal Program Information: HEERF Supplemental Assistance for Institutions of Higher Education (SAIHE) Program (ALN 84.425S) Criteria or Specific Requirement: Institutions must receive affirmative written consent before providing an emergency financial aid grant to a student?s account. Condition: The University credited emergency financial aid grants to students? accounts without getting affirmative written consent. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with federal guidelines over making emergency financial aid grants to students. Questioned Costs: None. Context: The University was allocated $991,895 of HEERF SAIHE funds, under Absolute Priority 6, which limited the use of these funds to making financial aid grants to students. The University appropriately used the funds to award additional financial aid grants; however, students did not have discretion about how to receive these grants. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over awarding and disbursing financial aid to ensure adherence to all federal guidelines. Views of Responsible Officials: The University applied for and received the SAIHE grant to assist our students. There was no definitive guidance on handling of the funds for the students. As a result, we posted the grant proceeds to the students? accounts.