Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns
acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
For 3 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by on-going calendar reminders as well as progress checks between the Director and Assistant Director.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 22 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Error records from 2 Error/Acknowledgement files received during the fiscal year were not corrected within the required timeframe.
Identification as a Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns
acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
For 3 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by on-going calendar reminders as well as progress checks between the Director and Assistant Director.
Federal Program Information: Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition: Certain loan notifications were not sent timely.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with loan notification requirements.
Questioned Costs: None.
Context: For 11 of 25 loan disbursements tested, the University did not notify the borrower within the required timeframe.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 22 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Error records from 2 Error/Acknowledgement files received during the fiscal year were not corrected within the required timeframe.
Identification as a Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns
acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
For 3 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by on-going calendar reminders as well as progress checks between the Director and Assistant Director.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 22 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Error records from 2 Error/Acknowledgement files received during the fiscal year were not corrected within the required timeframe.
Identification as a Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns
acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days.
For 3 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of Finding 2022-001.
Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely reporting to COD.
Views of Responsible Officials: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by on-going calendar reminders as well as progress checks between the Director and Assistant Director.
Federal Program Information: Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition: Certain loan notifications were not sent timely.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with loan notification requirements.
Questioned Costs: None.
Context: For 11 of 25 loan disbursements tested, the University did not notify the borrower within the required timeframe.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Program Level: Significant data elements were inaccurately reported for certain students.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 22 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS.
Error records from 2 Error/Acknowledgement files received during the fiscal year were not corrected within the required timeframe.
Identification as a Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS.
Views of Responsible Officials: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information.
Federal Program Information: Student Financial Assistance Cluster (Various ALNs)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public.
Condition: The University did not report the URL of its cash management contract to the Department as required.
Cause: Administrative oversight.
Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations.
Questioned Costs: None.
Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate.
Views of Responsible Officials: The link has been submitted to the Department of Education.