Finding 2023-001 Notices and Authorizations: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans
AL #: 84.268
Award Year: 2022-2023
Criteria: Per CFR 668.165(a)(1) through CFR 668.165a(2) before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans and which are from PLUS loans. The institution must notify the student or parent of:
1) The anticipated date and amount of disbursement.
2) The student’s or parent’s right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and
3) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement.
Condition: The written notifications were not provided to students in October 2022.
Cause: There was a change in the student financial aid system in the current year resulting in no automated notice being sent out. Under the prior system, this was an automated notification.
Effect: The proper notifications were not provided to the students or his or her parent.
Questioned Costs: None.
Context: Only the October 2022 notifications were not provided. Thus, this is not a system problem.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University designate one individual with the responsibility to verify all notifications are provided timely.
Views of Responsible Officials: During the transition from Jenzabar CX to Jenzabar JFA software, the process to notify students of their loan and TEACH grant disbursements and rights to cancel needed to be rebuilt. The process in CX was fully automated, while the process in JFA was not fully automated for the 2022-23 audit cycle. As a result, there were some students in October of 2022 that did not receive their required notification.
For the 2023-24 cycle, the Director of Financial Aid has worked with Jenzabar to establish a more automated process for these notifications. Two separate queries have been established to identify loan disbursements and TEACH recipients. Each query looks for disbursements that occurred that day and collects them in a batch. An automated “scheduler” then runs each group through a notification process where each student will receive an email to their Thomas More email account notifying them that they received the disbursement that day. The scheduler runs this process and sends notifications out at 8pm each evening. Any loan disbursements occur during normal business hours, and even if delayed, would not disburse past 6pm, so each disbursement that occurred that day will be caught by the scheduler by 8pm.
Finding 2023-002 Enrollment Reporting: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans, Pell Grants
AL #: 84.268, 84.063
Award Year: 2022-2023
Criteria: The Enrollment Reporting rosters are required to be completed and returned back within 15 days.
Condition: Two out of sixteen Enrollment Reporting rosters received were returned back after 15 days.
Cause: There was a change in the student information system in the current year resulting in delays in the Enrollment Reporting rosters being submitted.
Effect: The Enrollment Reporting rosters were not returned back within the required timeframe and therefore resulting in potential delays of student’s change in enrollment status.
Questioned Costs: None.
Context: Three out of sixteen Enrollment Reporting rosters were reported late.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University designate one individual with the responsibility of ensuring all Enrollment Reporting rosters are returned back timely.
Views of Responsible Officials: The Office of the Registrar submits the enrollment reports to the National Student Clearinghouse. Over the course of this past year, the office struggled with a new student information system and staff changes. To prevent reports being submitted late, everyone in the current staff has been trained on how to submit reports. The office has worked with representatives of the National Student Clearinghouse to assist with error reports. In addition, the due dates for submitting the reports have been updated to a more consistent timeframe each month. Each staff member in the Office of the Registrar has the list of dates when the reports are due. Furthermore, the staff hopes to schedule more training from the provider of the student information system to help process reports more accurately.
Finding 2023-002 Enrollment Reporting: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans, Pell Grants
AL #: 84.268, 84.063
Award Year: 2022-2023
Criteria: The Enrollment Reporting rosters are required to be completed and returned back within 15 days.
Condition: Two out of sixteen Enrollment Reporting rosters received were returned back after 15 days.
Cause: There was a change in the student information system in the current year resulting in delays in the Enrollment Reporting rosters being submitted.
Effect: The Enrollment Reporting rosters were not returned back within the required timeframe and therefore resulting in potential delays of student’s change in enrollment status.
Questioned Costs: None.
Context: Three out of sixteen Enrollment Reporting rosters were reported late.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University designate one individual with the responsibility of ensuring all Enrollment Reporting rosters are returned back timely.
Views of Responsible Officials: The Office of the Registrar submits the enrollment reports to the National Student Clearinghouse. Over the course of this past year, the office struggled with a new student information system and staff changes. To prevent reports being submitted late, everyone in the current staff has been trained on how to submit reports. The office has worked with representatives of the National Student Clearinghouse to assist with error reports. In addition, the due dates for submitting the reports have been updated to a more consistent timeframe each month. Each staff member in the Office of the Registrar has the list of dates when the reports are due. Furthermore, the staff hopes to schedule more training from the provider of the student information system to help process reports more accurately.
Finding 2023-003 Return of Funds: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans
AL #: 84.268
Award Year: 2022-2023
Criteria: Per CFR 668.22(e), the unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance to be earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew.
Condition: Two out of thirty-three students tested for return of funds were not returned timely.
Cause: There was a change in the student financial aid system in the current year resulting in delays in the funds being returned within 45 days.
Effect: The institution did not return funds within the required 45 days and therefore held onto funds longer than allowed.
Questioned Costs: None.
Context: Two out of thirty-three students tested for return of funds were not returned timely.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University implement a control to track potential return of funds in order to ensure they are returned within the required timeframe.
Views of Responsible Officials: Prior to the student information system transition, regular monitoring of the return of funds took place for Direct Loans, specifically for the returns associated with R2T4 calculations. During the transition, this process was not immediately replaced. It was noted during the audit cycle that issues existed within the new system related to returning funds and tickets were submitted to Jenzabar about the issues, specifically raising concerns about the timing of returns. Not all returns were being picked up by the process that collects the returns and sends them in batches to COD. Adjustments have been made to the system and testing has shown that all of the returns are being picked up now. The Financial Aid Office is also regularly monitoring returns again, similar to the process prior to the transition, and we are now monitoring both Direct Loan and Pell grant returns. This process is managed by an Excel spreadsheet of all Direct Loan and Pell grant returns that have been made in JFA. Any time a return of a Direct Loan or Pell grant is made in JFA, the return is added to the spreadsheet. A Financial Aid Counselor has a regular reminder on their calendar once per week to monitor each return to ensure that the full return process has taken place through COD and that the funds have been returned timely.
Finding 2023-001 Notices and Authorizations: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans
AL #: 84.268
Award Year: 2022-2023
Criteria: Per CFR 668.165(a)(1) through CFR 668.165a(2) before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans and which are from PLUS loans. The institution must notify the student or parent of:
1) The anticipated date and amount of disbursement.
2) The student’s or parent’s right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and
3) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement.
Condition: The written notifications were not provided to students in October 2022.
Cause: There was a change in the student financial aid system in the current year resulting in no automated notice being sent out. Under the prior system, this was an automated notification.
Effect: The proper notifications were not provided to the students or his or her parent.
Questioned Costs: None.
Context: Only the October 2022 notifications were not provided. Thus, this is not a system problem.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University designate one individual with the responsibility to verify all notifications are provided timely.
Views of Responsible Officials: During the transition from Jenzabar CX to Jenzabar JFA software, the process to notify students of their loan and TEACH grant disbursements and rights to cancel needed to be rebuilt. The process in CX was fully automated, while the process in JFA was not fully automated for the 2022-23 audit cycle. As a result, there were some students in October of 2022 that did not receive their required notification.
For the 2023-24 cycle, the Director of Financial Aid has worked with Jenzabar to establish a more automated process for these notifications. Two separate queries have been established to identify loan disbursements and TEACH recipients. Each query looks for disbursements that occurred that day and collects them in a batch. An automated “scheduler” then runs each group through a notification process where each student will receive an email to their Thomas More email account notifying them that they received the disbursement that day. The scheduler runs this process and sends notifications out at 8pm each evening. Any loan disbursements occur during normal business hours, and even if delayed, would not disburse past 6pm, so each disbursement that occurred that day will be caught by the scheduler by 8pm.
Finding 2023-002 Enrollment Reporting: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans, Pell Grants
AL #: 84.268, 84.063
Award Year: 2022-2023
Criteria: The Enrollment Reporting rosters are required to be completed and returned back within 15 days.
Condition: Two out of sixteen Enrollment Reporting rosters received were returned back after 15 days.
Cause: There was a change in the student information system in the current year resulting in delays in the Enrollment Reporting rosters being submitted.
Effect: The Enrollment Reporting rosters were not returned back within the required timeframe and therefore resulting in potential delays of student’s change in enrollment status.
Questioned Costs: None.
Context: Three out of sixteen Enrollment Reporting rosters were reported late.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University designate one individual with the responsibility of ensuring all Enrollment Reporting rosters are returned back timely.
Views of Responsible Officials: The Office of the Registrar submits the enrollment reports to the National Student Clearinghouse. Over the course of this past year, the office struggled with a new student information system and staff changes. To prevent reports being submitted late, everyone in the current staff has been trained on how to submit reports. The office has worked with representatives of the National Student Clearinghouse to assist with error reports. In addition, the due dates for submitting the reports have been updated to a more consistent timeframe each month. Each staff member in the Office of the Registrar has the list of dates when the reports are due. Furthermore, the staff hopes to schedule more training from the provider of the student information system to help process reports more accurately.
Finding 2023-002 Enrollment Reporting: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans, Pell Grants
AL #: 84.268, 84.063
Award Year: 2022-2023
Criteria: The Enrollment Reporting rosters are required to be completed and returned back within 15 days.
Condition: Two out of sixteen Enrollment Reporting rosters received were returned back after 15 days.
Cause: There was a change in the student information system in the current year resulting in delays in the Enrollment Reporting rosters being submitted.
Effect: The Enrollment Reporting rosters were not returned back within the required timeframe and therefore resulting in potential delays of student’s change in enrollment status.
Questioned Costs: None.
Context: Three out of sixteen Enrollment Reporting rosters were reported late.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University designate one individual with the responsibility of ensuring all Enrollment Reporting rosters are returned back timely.
Views of Responsible Officials: The Office of the Registrar submits the enrollment reports to the National Student Clearinghouse. Over the course of this past year, the office struggled with a new student information system and staff changes. To prevent reports being submitted late, everyone in the current staff has been trained on how to submit reports. The office has worked with representatives of the National Student Clearinghouse to assist with error reports. In addition, the due dates for submitting the reports have been updated to a more consistent timeframe each month. Each staff member in the Office of the Registrar has the list of dates when the reports are due. Furthermore, the staff hopes to schedule more training from the provider of the student information system to help process reports more accurately.
Finding 2023-003 Return of Funds: (Significant Deficiency)
Federal Agency: Department of Education
Program: Federal Direct Student Loans
AL #: 84.268
Award Year: 2022-2023
Criteria: Per CFR 668.22(e), the unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance to be earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew.
Condition: Two out of thirty-three students tested for return of funds were not returned timely.
Cause: There was a change in the student financial aid system in the current year resulting in delays in the funds being returned within 45 days.
Effect: The institution did not return funds within the required 45 days and therefore held onto funds longer than allowed.
Questioned Costs: None.
Context: Two out of thirty-three students tested for return of funds were not returned timely.
Repeat Finding: Not considered a repeat finding.
Recommendation: We recommend the University implement a control to track potential return of funds in order to ensure they are returned within the required timeframe.
Views of Responsible Officials: Prior to the student information system transition, regular monitoring of the return of funds took place for Direct Loans, specifically for the returns associated with R2T4 calculations. During the transition, this process was not immediately replaced. It was noted during the audit cycle that issues existed within the new system related to returning funds and tickets were submitted to Jenzabar about the issues, specifically raising concerns about the timing of returns. Not all returns were being picked up by the process that collects the returns and sends them in batches to COD. Adjustments have been made to the system and testing has shown that all of the returns are being picked up now. The Financial Aid Office is also regularly monitoring returns again, similar to the process prior to the transition, and we are now monitoring both Direct Loan and Pell grant returns. This process is managed by an Excel spreadsheet of all Direct Loan and Pell grant returns that have been made in JFA. Any time a return of a Direct Loan or Pell grant is made in JFA, the return is added to the spreadsheet. A Financial Aid Counselor has a regular reminder on their calendar once per week to monitor each return to ensure that the full return process has taken place through COD and that the funds have been returned timely.