FAC Explorer

Finding 541007 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 350613
Organization: Thomas Jefferson University (PA)
Auditor: Pricewaterhousecoopers

AI Summary

  • Core Issue: The University failed to meet several compliance requirements related to student financial assistance, including notification of loan disbursements and timely enrollment reporting.
  • Impacted Requirements: Key regulations under 34 CFR 668.165, 668.56, 668.21-22, and 685.309 were not followed, affecting disbursement notifications, verification processes, and enrollment status reporting.
  • Recommended Follow-Up: Management should improve training for new staff and allocate more resources to ensure compliance with all federal requirements.

Finding Text

Finding 2024-001 Special Tests and Provisions – Student Financial Assistance Cluster (Significant Deficiency) Grantor(s): Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 93.364, 93.342, 93.342, 84.007, 84.033, 84.063, 84.038, 84.268 Title: Nursing Student Loans (NSL), Health Professions Student Loans, Including Primary Care Loans And Loans For Disadvantaged Students (HPSL/PCL/LDS), Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins Loan Program, Federal Direct Student Loans Award Year: 7/2023 – 6/2024 Award #: N/A Pass-through Number: N/A Criteria 34 CFR 668.165 which requires the institution, in advance of disbursement, to provide a general notification to all students receiving Title IV program funds including (1) the anticipated date and amount of the disbursement; (2) the student's or parent's right to cancel all or a portion of that loan or loan disbursement; 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. (Disbursements to or on Behalf of Students) 34 CFR 668.56 which indicates the FAFSA information that an institution and an applicant are required to verify. (Verification) 34 CFR 668.21-22 which includes the requirements for determining the amount of Title IV funding to be returned to the Department of Education as well as the required order and timeframe for return of Title IV funds. (Return of Title IV Funds) 34 CFR 685.309 and 34 CFR 674.19 which states unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the school discovers that (1) a student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended, or (2) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Student status changes are required to be reported at both the “Campus Level” and “Program-Level” as each have separate record types. (Enrollment Reporting) Condition Based on our testing, we noted the following: • For 1 student of the 50 sampled to test Disbursements to or on Behalf of Students, we noted that the loan disbursement notification letter sent that would include, in writing (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; 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, was not sent. However, the student did sign a Master Promissory Note (MPN), in which the student promises to repay the loan they received. • For 4 students of the 31 sampled to test Verification, we noted that information was verified incorrectly between the submitted documentation and the student aid application. Additionally, in one instance the verification worksheet was not maintained. For 1 student of the 18 sampled to test Return of Title IV funds, the students funds were not returned within the 45-day window. For 1 student of the 18 sampled to test Return of Title IV funds, the Return of Title IV funds were calculated incorrectly. However, this student ultimately returned more than was required by the calculation. • For 20 students of the 25 sampled to test Enrollment Reporting, we noted that there were instances of noncompliance, including: o For 9 students, the student’s enrollment change to ‘Graduated’ was not reported to NSLDS. o For 5 students, enrollment status was not reported timely by the University and/or the Service Provider to NSLDS (within 60-day requirement). o For 3 students, the enrollment status should have been reported as Leave of Absence (LOA) to NSLDS but was instead reported as ‘Withdrawn." Additionally, the status was not reported timely by the University and/or the Service Provider to NSLDS. o For 1 student, the NSLDS Campus Level effective date did not agree to that of the student file and NSLDS Program Level. o For 1 student, the NSLDS Program Level effective date did not agree to that of the student file and NSLDS Campus Level. o For 1 student, the date of graduation per transcript did not agree to the date reported to NSLDS on the program and campus level. Cause The cause of this finding was due to insufficient resources and need for increased training of new staff members within the Student Financial Aid office and Registrar's office. Effect The University did not comply with the specific requirements from the Department of Education, and, in certain cases, the Department did not receive information timely and/or accurately. However, there was no impact on federal funds received, returned, or disbursed to students. Questioned Costs None. Recommendation Management should enhance their current controls in place to ensure new staff have the appropriate training and add additional resources, as available, to meet all compliance requirements. Management’s View and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.

Categories

Student Financial Aid Special Tests & Provisions Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 540999 2024-001
    Significant Deficiency
  • 541000 2024-001
    Significant Deficiency
  • 541001 2024-001
    Significant Deficiency
  • 541002 2024-001
    Significant Deficiency
  • 541003 2024-001
    Significant Deficiency
  • 541004 2024-001
    Significant Deficiency
  • 541005 2024-001
    Significant Deficiency
  • 541006 2024-001
    Significant Deficiency
  • 541008 2024-001
    Significant Deficiency
  • 541009 2024-001
    Significant Deficiency
  • 541010 2024-001
    Significant Deficiency
  • 541011 2024-001
    Significant Deficiency
  • 541012 2024-001
    Significant Deficiency
  • 541013 2024-001
    Significant Deficiency
  • 541014 2024-001
    Significant Deficiency
  • 541015 2024-001
    Significant Deficiency
  • 541016 2024-001
    Significant Deficiency
  • 541017 2024-001
    Significant Deficiency
  • 541018 2024-001
    Significant Deficiency
  • 541019 2024-001
    Significant Deficiency
  • 541020 2024-001
    Significant Deficiency
  • 541021 2024-001
    Significant Deficiency
  • 541022 2024-001
    Significant Deficiency
  • 1117441 2024-001
    Significant Deficiency
  • 1117442 2024-001
    Significant Deficiency
  • 1117443 2024-001
    Significant Deficiency
  • 1117444 2024-001
    Significant Deficiency
  • 1117445 2024-001
    Significant Deficiency
  • 1117446 2024-001
    Significant Deficiency
  • 1117447 2024-001
    Significant Deficiency
  • 1117448 2024-001
    Significant Deficiency
  • 1117449 2024-001
    Significant Deficiency
  • 1117450 2024-001
    Significant Deficiency
  • 1117451 2024-001
    Significant Deficiency
  • 1117452 2024-001
    Significant Deficiency
  • 1117453 2024-001
    Significant Deficiency
  • 1117454 2024-001
    Significant Deficiency
  • 1117455 2024-001
    Significant Deficiency
  • 1117456 2024-001
    Significant Deficiency
  • 1117457 2024-001
    Significant Deficiency
  • 1117458 2024-001
    Significant Deficiency
  • 1117459 2024-001
    Significant Deficiency
  • 1117460 2024-001
    Significant Deficiency
  • 1117461 2024-001
    Significant Deficiency
  • 1117462 2024-001
    Significant Deficiency
  • 1117463 2024-001
    Significant Deficiency
  • 1117464 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $123.79M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $20.57M
93.767 Children's Health Insurance Program $15.02M
84.063 Federal Pell Grant Program $8.01M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $4.77M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $2.08M
84.038 Federal Perkins Loan Program_federal Capital Contributions $1.46M
84.033 Federal Work-Study Program $871,752
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $808,282
84.007 Federal Supplemental Educational Opportunity Grants $676,382
93.940 Hiv Prevention Activities Health Department Based $534,094
93.732 Mental and Behavioral Health Education and Training Grants $528,072
93.268 Immunization Cooperative Agreements $505,616
93.959 Block Grants for Prevention and Treatment of Substance Abuse $499,741
93.364 Nursing Student Loans $455,333
93.884 Primary Care Training and Enhancement $437,101
93.113 Environmental Health $436,154
93.137 Community Programs to Improve Minority Health $382,102
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $375,279
93.855 Allergy and Infectious Diseases Research $288,434
93.264 Nurse Faculty Loan Program (nflp) $285,261
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $272,495
93.958 Block Grants for Community Mental Health Services $271,503
93.186 National Research Service Award in Primary Care Medicine $265,590
81.086 Conservation Research and Development $213,540
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $204,357
93.839 Blood Diseases and Resources Research $187,749
93.226 Research on Healthcare Costs, Quality and Outcomes $184,278
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $170,132
93.867 Vision Research $161,621
93.926 Healthy Start Initiative $155,173
93.342 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students $149,500
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $141,107
93.350 National Center for Advancing Translational Sciences $121,953
43.003 Exploration $118,390
21.027 Coronavirus State and Local Fiscal Recovery Funds $110,010
93.630 Developmental Disabilities Basic Support and Advocacy Grants $105,229
93.396 Cancer Biology Research $93,408
47.079 Office of International Science and Engineering $79,707
93.914 Hiv Emergency Relief Project Grants $71,258
93.250 Geriatric Academic Career Awards Department of Health and Human Services $71,181
16.835 Body Worn Camera Policy and Implementation $70,384
15.670 Adaptive Science $63,888
11.307 Economic Adjustment Assistance $63,073
93.071 Medicare Enrollment Assistance Program $50,924
93.860 Emerging Infections Sentinel Networks $48,181
12.340 Naval Medical Research and Development $47,286
93.398 Cancer Research Manpower $46,939
93.103 Food and Drug Administration Research $46,579
93.307 Minority Health and Health Disparities Research $46,110
93.247 Advanced Nursing Education Workforce Grant Program $44,403
93.145 Hiv-Related Training and Technical Assistance $43,983
93.859 Biomedical Research and Research Training $40,615
93.435 The Innovative Cardiovascular Health Program $37,330
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $35,934
93.994 Maternal and Child Health Services Block Grant to the States $35,266
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $34,588
45.162 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $33,499
47.049 Mathematical and Physical Sciences $32,251
93.351 Research Infrastructure Programs $30,794
93.217 Family Planning Services $27,018
93.361 Nursing Research $24,388
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $23,701
93.172 Human Genome Research $23,636
93.279 Drug Use and Addiction Research Programs $23,017
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B $21,934
93.124 Nurse Anesthetist Traineeship $21,163
95.007 Research and Data Analysis $21,068
14.902 Lead Technical Studies Grants $20,954
93.325 Paralysis Resource Center $20,800
11.619 Arrangements for Interdisciplinary Research Infrastructure $19,485
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $18,764
93.173 Research Related to Deafness and Communication Disorders $17,271
84.425 Heerf $16,500
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $14,405
93.865 Child Health and Human Development Extramural Research $13,791
93.110 Maternal and Child Health Federal Consolidated Programs $13,591
93.310 Trans-Nih Research Support $13,510
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $12,271
93.283 Centers for Disease Control and Prevention Investigations and Technical Assistance $10,437
47.076 Stem Education (formerly Education and Human Resources) $10,199
93.755 Surveillance for Diseases Among Immigrants and Refugees Financed in Part by Prevention and Public Health Funds (pphf) $10,132
93.242 Mental Health Research Grants $9,972
12.420 Military Medical Research and Development $8,870
93.136 Injury Prevention and Control Research and State and Community Based Programs $8,153
93.121 Oral Diseases and Disorders Research $7,470
93.838 Lung Diseases Research $6,904
93.399 Cancer Control $4,405
93.RD Advanced Development of Multivalent Vaccine Candidate for Filovirus and Lassa Fever $3,897
12.300 Basic and Applied Scientific Research $3,321
93.393 Cancer Cause and Prevention Research $3,221
93.866 Aging Research $2,527
93.395 Cancer Treatment Research $2,425
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $2,297
93.273 Alcohol Research Programs $1,351
93.397 Cancer Centers Support Grants $542
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $336
93.184 Disabilities Prevention $7
17.280 Wioa Dislocated Worker National Reserve Demonstration Grants $-78
93.788 Opioid Str $-127
21.019 Coronavirus Relief Fund $-241
93.394 Cancer Detection and Diagnosis Research $-1,417
93.837 Cardiovascular Diseases Research $-5,360