Finding 1159573 (2025-001)

Finding 2025-001 Federal program: Federal Direct Student Loans Federal Agency: U.S. Department of Education ALN #: 84.268 Award Year: 2024/2025 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting – Title IV Programs Criteria: Under 34 CFR 690.83, Institutions must report to the Common Origination and Disbursement (“COD”) system 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. Condition: Of forty students judgmentally selected for Title IV testing, one student was reported to the COD system beyond the 15 calendar days required under 34 CFR 690.83. Cause and Effect: The above finding resulted from a cancellation of student aid by the University in its financial aid management system. Due to the student’s Direct Loan being fully canceled and an identified system defect impacting Borrower Based Academic Year (BBAY) Direct Loans, the system defaulted the attendance cost value to a null (non- numeric) value. This prevented the system generated extraction of the Direct Loan cancellation amount from being reported timely to COD within the required 15 calendar days. Questioned Costs: None noted. Identified as a Repeat Finding: No Recommendations: The University should ensure it implements a preventive control to review all students who cancel their awarded Direct loan amount in the financial aid system to ensure the students are reported to the COD system in a correct and timely manner. Views of Responsible Officials: The University conducted a full review of the population of cancellations for the fiscal year ending May 31, 2025, comprising of 53 students. The review identified seven instances of late reporting, all of which were previously corrected through the University’s monthly disbursement reconciliation processes, but beyond the 15 calendar day reporting requirement. Each of the identified instances resulted from a system defect which caused canceled BBAY Direct Loans reduced to zero (“0”) to receive an automatic null attendance cost. Due to the automatic null value, the record was excluded from the financial aid management system to COD record extraction process. The University has created a report to identify instances where the attendance cost value is null. When identified, action will be taken to populate the attendance cost to zero and allow extraction. The records will be subsequently verified to confirm extraction for submission to COD and reports will be reviewed weekly by the supervisor. The University will continue to review and implement additional controls to ensure disbursement records are submitted to COD within 15 calendar days. To ensure enhanced oversight and monitoring controls are effective to maintain compliance and timely reporting to COD, management will incorporate this review into their routine Assurance validation processes for students from the identified population.