Finding Text
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.