ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 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 the 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 NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1.Of the 40 students tested, there was 15 students who withdrew or graduated whose status change was not reported accurately to the NSLDS. The student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew or graduated whose status change were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Following guidance provided by Plante & Moran, PLLC and the Department of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective fall 2022 to address correct enrollment status change reporting: ?Adopt the use of the published academic semester end date for enrollment reporting versus the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that the published end of an academic semester, per the academic calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ?Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date that registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated due to having attended at least 60 percent of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting, as the last date of attendance is supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure students who are unofficial withdrawals at the end of an academic semester are accurately identified and adjust staffing resources as necessary to account for critical time periods, such as the period between CMU's fall and spring semesters when the University is closed. This will be necessary due to using the published last date of the semester instead of the end of payment period date that was used in prior years. ?The planned timeline to complete corrective actions is February 2023 to account for end of fall 2022 grading processes and manual updating of NSLDS, as necessary, for identified unofficial withdrawals.
ALN. 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 - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $7,705 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on consistent semester end dates. Context - There were three errors that contributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2.Of the 60 students tested there were 18 students to whom the University had returned the funds untimely (45 days if the student attended, 30 days if they never attended). 3.Of the 60 students tested, there were 4 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the students were selected for testing for the audit. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - The University agrees with the finding. The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked, as appropriate. This will clarify the procedures being used for the return to Title IV process. ?The procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?The methodology for dates being used for the end of semester and the date of determination will be clearly documented for each semester, along with the actual dates used. For nonmodular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the AskRegs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to ensure that all required returns for a given semester have occurred. This will address students who were also missed in the prior year process.