University of HartfordHigher Education

2024-001 – Perkins Loan Recordkeeping and Record Retention Federal Agency: U.S. Department of Education Federal Program Title: Federal Perkins Loan Program Federal Assistance Listing Number: 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper master promissory note (MPN) and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)). Condition: Original promissory notes were unable to be located. Questioned costs: None. Context: During our testing, we noted 4 instances out of 40 open Perkins loans tested where the University was unable to locate the original promissory note. Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students in order to ensure that recordkeeping and retention regulations were being followed. Effect: Open loan balances for these loans are not supported by an original promissory note. Repeat finding: Yes, 2023-001. Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Views of responsible officials: Management agrees with the finding. Please refer to the attached corrective action plan.

2023-001 – Perkins Loan Recordkeeping and Record Retention  Federal Agency: U.S. Department of Education Federal Program Title: Federal Perkins Loan Program Federal Assistance Listing Number: 84.038 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)). Condition: Original promissory notes were unable to be located. Questioned costs: None. Context: During our testing, we noted 6 instances out of 40 open Perkins loans tested where the University was unable to locate the original promissory note. Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students in order to ensure that recordkeeping and retention regulations were being followed. Effect: Open loan balances for these loans are not supported by an original promissory note. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Views of responsible officials: Management agrees with the finding.

2023-002 – Gramm-Leach-Bliley Act (GLBA)  Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, and 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protest student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None. Context: During our testing of the University’s information technology, it was noted that the University does not have an active written information security program in place that addressed all seven elements as required by the Gramm-Leach-Bliley Act. Cause: The University has continued to make progress in updating the Universities written security program to become compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No. Recommendation: We recommend the University designate an individual to oversee the information security function and work to update the Universities written security program to ensure compliance with all the standards. Views of responsible officials: Management agrees with the finding.

2023-003 – National Student Loan Data System (NSLDS) Reporting  Federal Agency: U.S. Department of Education Federal Program Title: Federal Pell Grant Program; Federal Direct Loan Program Federal Assistance Listing Number: 84.063 and 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted: -One student out of a sample of 40 students tested was reported to the NSLDS with an enrollment status of Full-time but was never updated subsequently to an enrollment status of Graduated for graduating from the University. This effected both the campus-level and program-level records in the NSLDS. -One student out of the sample of 40 students tested was reported to the NSLDS with the incorrect effective date on the campus-level and program-level in NSLDS. -Three students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: The University's system for which the information is pulled and sent to the NSLDS was not updated for the proper enrollment information per the University's records that are outside of the system. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-003. Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported timely in accordance with applicable regulations. Views of responsible officials: Management agrees with the finding.

2023-004 – Tier One and Tier Two Arrangements  Federal Agency: U.S. Department of Education Federal Program Title: Federal Pell Grant Program; Federal Direct Loan Program Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, and 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations 34 CFR 668.164(e) and (f), an institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. The regulation establishes two different types of arrangements between schools and financial account providers: Tier One or Tier Two. Under both arrangements, a school must provide to the Department of Education an up-to-date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data information. Condition: Certain arrangement criteria’s were not reported to the Department o Education. Questioned costs: None Context: During testing, it was determined that the University has a Tier One contract with a third-party. Per review of the Federal Student Aid site, under "Cash Management Contracts”, it was determined that the University had not provided a URL to the Department of Education regarding its Tier One arrangement. Cause: This requirement was new for the University during the year; however, due to capacity and demands on federal requirements, this is still a work in process. Effect: Noncompliance can lead to the University potentially losing Title IV aid eligibility. Repeat finding: No Recommendation: We recommend the University review its policies and procedures on reporting requirements to the Department if Education in respects to these requirements. Views of responsible officials: Management agrees with the finding.

2022-001 ? Perkins Loan Recordkeeping and Record Retention Federal Agency: U.S. Department of Education Federal Program Title: Federal Perkins Loan Program Federal Assistance Listing Number: 84.038 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: An institution shall keep original promissory notes and repayment schedules until Perkins loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container (34 CFR 674.19(e)(4)). Condition: Original promissory notes were unable to be located. Questioned costs: None. Context: During our testing, we noted 7 instances out of 40 open Perkins loans tested where the University was unable to locate the original promissory note. Cause: The University did not have the appropriate policies and procedures in place when Perkins loans were awarded to students in order to ensure that recordkeeping and retention regulations were being followed. Effect: Open loan balances for these loans are not supported by an original promissory note. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Views of responsible officials: Management agrees with the finding.

2022-002 ? Gramm-Leach-Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, and 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: In accordance with the Gramm-Leach-Bliley Act and the Code of Federal Regulations 16 CFR 314.4(e), the University is required to implement policies and procedures to ensure that personnel are able to enact you information security program by providing personnel with security awareness training that is updated as necessary to reflect the identified risk by the risk assessment. Condition: The University risk assessment did not include security awareness training. Questioned costs: None. Context: During our testing of the University?s risk assessment, it was noted that security awareness training was not identified. Cause: The University did not have all required elements of GLBA documented in their risk assessment. Effect: Noncompliance with GLBA requirements. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and policies around their risk assessment under the requirements of GLBA. Views of responsible officials: Management agrees with the finding.

2022-003 ? National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Federal Pell Grant Program; Federal Direct Loan Program Federal Assistance Listing Number: 84.063 and 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted: ? 1 student out of a sample of 40 students tested was reported to the NSLDS with an enrollment status of Withdraw but was never updated subsequently to an enrollment status of Graduated for graduating from the University. This effected both the campus-level and program-level records in the NSLDS. ? 16 students out of the sample of 40 students tested were reported to the NSLDS with the incorrect effective date on the campus-level and program-level in NSLDS. ? 2 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. Cause: The University's system for which the information is pulled and sent to the NSLDS was not updated for the proper enrollment information per the University's records that are outside of the system. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2021-001. Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported timely in accordance with applicable regulations. Views of responsible officials: Management agrees with the finding.

Criteria Institutions are required to report enrollment information under the Pell grant and the Direct programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035 (Pell, 34 CFR 690.83(b)(2) Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Under the Pell grant and Direct loan programs, 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. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Unless an institution expects to submit its next updated enrollment report to the Department within the next 60 days, an institution must notify NSLDS within 30 days after the date that the institution discovers that (1) a Direct loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended. Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment reports through rosters provided to the NSC. Of the forty (40) students with enrollment changes we selected for test work, we noted two students whose changes in enrollment status were not timely or accurately transmitted to NSLDS, as follows: For one (1) of the students the University did not accurately report the student as graduated within NSLDS. The University had the incorrect student social security number input into the database and therefore no record for the student was found in NSLDS. The University updated the record on August 5, 2022. For one (1) of the students the University did not accurately report the student as graduated status within NSLDS. The student was reported as full-time status until reported as withdrawn at the beginning of the fall 2021 semester. Cause The University?s internal control processes did not operate consistently to ensure that all enrollment status changes are submitted timely and accurately to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the University perform a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected. View of University Officials The University agrees with the finding. The University has put a plan in place to review the additional section of errors to correct any future errors. Additionally, the University plans to work closely with NSC to identify all areas that need to be reviewed on the website, to ensure all students are reported accurately. Student enrollment status will be verified to ensure the enrollment section has the correct status that is sent to NSLDS when the graduate file is submitted to the National Student Clearinghouse.

Criteria - According to 34 CFR Section 685.309 and 34 CFR section 690.83(b), under the Federal Direct and Pell loan programs, institutions must complete and return the Enrollment Reporting roster file via the National Students Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school and the 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. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NLSDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment reports through rosters provided to the NSC. Of the forty (40) students with enrollment changes we selected for test work, we noted two students whose changes in enrollment status were not timely or accurately transmitted to NSLDS, as follows: - For two (2) of the students the University was notified of the student?s status change from full-time to graduated in May 2020, when the student graduated with a degree. Accordingly, the status change should have been transmitted after the spring semester, within 60 days of being notified of the change. However, the University did not report status change until the submission of the fall 2020 enrollment roster, 123 days following notification of the status changes. In addition, the status change was reported to NSLDS as withdrawn instead of graduated. Cause The University?s internal control processes did not operate consistently to ensure that all enrollment status changes are submitted timely and accurately to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies.

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