EIN: 111788788
UEI: SVZSJHR2A4T6
Audited by: Grant Thornton LLP
Cognizant agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 17, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 17, 2026 (9 days from today).
What is a management decision? →FAC accepted this audit on March 20, 2025 — management decision was due September 20, 2025.
FAC accepted this audit on January 8, 2024 — management decision was due July 8, 2024.
FAC accepted this audit on February 9, 2023 — management decision was due August 9, 2023.
Finding 2022-001 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. There are two categories of enrollment information; ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For one (1) student, the incorrect Campus-Level Enrollment Status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (e.g., in the NSLDS submission immediately following the date the student was determined to have graduated, a status of full time was incorrectly reported instead). For this one (1) student, and an additional twenty seven (27) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after their graduation effective date (e.g., in the NSLDS submission immediately following the graduation effective date, a status of full-time was incorrectly reported instead of withdrawn or graduated). ? For one (1) additional student, the incorrect Program-Level Enrollment Status was reported to NSLDS after their graduation effective date. Additionally for this one (1) student, the Program-Level Enrollment Status was reported to NSLDS 106 days after the date of determination of a Program-Level enrollment change, outside of the required 60-day timeframe. In total, we identified one or more of the instances of noncompliance described above in twenty nine (29) of the forty (40) students selected for testing. As enrollment reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Due to the timing of the 2021 finding, management was unable to implement the corrective action plan in time for fiscal year 2022, resulting in the repeat finding. Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The Institute should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Additionally, the Institute should consider only reporting students with campus-level or program-level changes with each NSLDS submission, rather than the entire student roster. Views of Responsible Officials and Planned Corrective Action: The Institute will modify End of Term and Graduate/Withdrawal files with respect to timing and who is included to NSC/NSLDS files to ensure timely reporting of change of status. End of term reporting will continue on existing schedule to capture student status at end of term. Graduating students will be reported on Graduate File 3 weeks after end of term. Subsequently, ONLY those students who are potential graduates and have not yet been cleared will be reported as ?Withdrawn? as a temporary status until they are cleared for graduation, upon which their status will be manually updated.
Show full finding ▾Hide full finding ▴Finding 2022-001 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. There are two categories of enrollment information; ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For one (1) student, the incorrect Campus-Level Enrollment Status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (e.g., in the NSLDS submission immediately following the date the student was determined to have graduated, a status of full time was incorrectly reported instead). For this one (1) student, and an additional twenty seven (27) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after their graduation effective date (e.g., in the NSLDS submission immediately following the graduation effective date, a status of full-time was incorrectly reported instead of withdrawn or graduated). ? For one (1) additional student, the incorrect Program-Level Enrollment Status was reported to NSLDS after their graduation effective date. Additionally for this one (1) student, the Program-Level Enrollment Status was reported to NSLDS 106 days after the date of determination of a Program-Level enrollment change, outside of the required 60-day timeframe. In total, we identified one or more of the instances of noncompliance described above in twenty nine (29) of the forty (40) students selected for testing. As enrollment reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Due to the timing of the 2021 finding, management was unable to implement the corrective action plan in time for fiscal year 2022, resulting in the repeat finding. Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The Institute should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Additionally, the Institute should consider only reporting students with campus-level or program-level changes with each NSLDS submission, rather than the entire student roster. Views of Responsible Officials and Planned Corrective Action: The Institute will modify End of Term and Graduate/Withdrawal files with respect to timing and who is included to NSC/NSLDS files to ensure timely reporting of change of status. End of term reporting will continue on existing schedule to capture student status at end of term. Graduating students will be reported on Graduate File 3 weeks after end of term. Subsequently, ONLY those students who are potential graduates and have not yet been cleared will be reported as ?Withdrawn? as a temporary status until they are cleared for graduation, upon which their status will be manually updated.
Corrective Action: Modify End of Term and Graduate/Withdrawal files with respect to timing and who is included to NSC/NSLDS files to ensure timely reporting of change of status. End of term reporting will continue on existing schedule to capture student status at end of term. Graduating students will be reported on Graduate File 3 weeks after end of term. Subsequently, ONLY those students who are potential graduates and have not yet been cleared will be reported as ?Withdrawn? as a temporary status until they are cleared for graduation, upon which their status will be manually updated. Proposed Completion Date: Implementation began with Fall 2022 graduates and will continue every term
2021-002
FAC accepted this audit on September 27, 2022 — management decision was due March 27, 2023.
Finding 2021-001 - Special Tests and Provisions - Verification (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Supplemental Education Opportunity Grant Program (84.007) Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2020-2021 Criteria and Context: Pursuant to 34 CFR Section 668.54(a), except as provided in paragraph (b) of 34 CFR Section 668.54, an institution must require an applicant whose Free Application for Federal Student Aid (?FAFSA?) FAFSA information is selected for verification by the Secretary, to verify the information specified by the Secretary pursuant to 34 CFR Section 668.56. Acceptable documentation for verification is further defined in 34 CFR Section 668.57, and specifically for the 2019-2020 award year, in Federal Register Volume 83, Number 60. From a selection of ninety (90) students, for which verification procedures were noted to be performed by the Institute, we identified three (3) students for which the information selected for verification did not agree with supporting records provided by the student. Condition, Cause, and Effect: Of the ninety (90) students selected for verification testing, we identified the following instances of noncompliance: ? For one (1) student, the number of household members and number of household members enrolled in college reported on her Institutional Student Information Record (?ISIR?) did not agree with the numbers reported on her signed student verification worksheet. The ISIR information was subsequently updated in PeopleSoft, the Institute?s financial aid system, and there was no change to the student?s expected family contribution (?EFC?). ? For one (1) student, the parents? adjusted gross income reported on the student?s ISIR did not agree with the adjusted gross income on their parents? tax return. The ISIR information was subsequently updated in PeopleSoft, and there was no change to the student?s EFC. ? For 1 student, the student?s adjusted gross income and U.S income tax paid reported on the student?s ISIR did not agree with the adjusted gross income and U.S income tax paid reported on their tax return. The ISIR information was subsequently updated in PeopleSoft, and there was no change to the student?s EFC. As verification procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Due to the timing of the 2020 finding, management was unable to implement the corrective action plan in time for fiscal year 2021, resulting in the repeat finding. Questioned Costs: None noted. Identified as a Repeat Finding: Yes Recommendation: The Institute should review its policies pertaining to verification and implement changes to enhance or clarify existing procedures in accordance with 34 CFR Part 668, Subpart E - Verification and Updating of Student Aid Application Information. Further, additional training should be provided to staff to increase their awareness of necessary protocols for verifying an applicant?s FAFSA information.
Show full finding ▾Hide full finding ▴Finding 2021-001 - Special Tests and Provisions - Verification (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Supplemental Education Opportunity Grant Program (84.007) Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2020-2021 Criteria and Context: Pursuant to 34 CFR Section 668.54(a), except as provided in paragraph (b) of 34 CFR Section 668.54, an institution must require an applicant whose Free Application for Federal Student Aid (?FAFSA?) FAFSA information is selected for verification by the Secretary, to verify the information specified by the Secretary pursuant to 34 CFR Section 668.56. Acceptable documentation for verification is further defined in 34 CFR Section 668.57, and specifically for the 2019-2020 award year, in Federal Register Volume 83, Number 60. From a selection of ninety (90) students, for which verification procedures were noted to be performed by the Institute, we identified three (3) students for which the information selected for verification did not agree with supporting records provided by the student. Condition, Cause, and Effect: Of the ninety (90) students selected for verification testing, we identified the following instances of noncompliance: ? For one (1) student, the number of household members and number of household members enrolled in college reported on her Institutional Student Information Record (?ISIR?) did not agree with the numbers reported on her signed student verification worksheet. The ISIR information was subsequently updated in PeopleSoft, the Institute?s financial aid system, and there was no change to the student?s expected family contribution (?EFC?). ? For one (1) student, the parents? adjusted gross income reported on the student?s ISIR did not agree with the adjusted gross income on their parents? tax return. The ISIR information was subsequently updated in PeopleSoft, and there was no change to the student?s EFC. ? For 1 student, the student?s adjusted gross income and U.S income tax paid reported on the student?s ISIR did not agree with the adjusted gross income and U.S income tax paid reported on their tax return. The ISIR information was subsequently updated in PeopleSoft, and there was no change to the student?s EFC. As verification procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Due to the timing of the 2020 finding, management was unable to implement the corrective action plan in time for fiscal year 2021, resulting in the repeat finding. Questioned Costs: None noted. Identified as a Repeat Finding: Yes Recommendation: The Institute should review its policies pertaining to verification and implement changes to enhance or clarify existing procedures in accordance with 34 CFR Part 668, Subpart E - Verification and Updating of Student Aid Application Information. Further, additional training should be provided to staff to increase their awareness of necessary protocols for verifying an applicant?s FAFSA information.
NYIT agrees with the three findings related to Verification. The Corrective Action Plan below submitted with the 2019 audit was implemented in the 2021-2022 academic year, as the 2020-2021 academic year had ended at the time we received the Final Determination on February 22, 2022. Senior level staff in the Office of Financial Aid will perform periodic reviews of selected verifications completed by all junior level staff, regardless of their hire date. For all upcoming academic years, these reviews will occur minimally on a monthly basis. The Office is adding a dual employee/peer review process for selected verifications. In addition to the senior-level review, the Office will ensure each junior level staff member conducts periodic reviews of verifications performed by their colleagues. The Office is instituting a requirement for all staff to utilize an internal verification checklist when completing the process and to keep a copy of the completed checklist in each student?s file. The checklist will be utilized in conducting both the senior and peer level reviews described above.
2020-001
Finding 2021-002 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2020-2021 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. There are two categories of enrollment information; ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For nine (9) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (e.g., in the NSLDS submission immediately following the date the student was determined to have graduated, a status of full time was incorrectly reported instead). For eight (8) of these nine (9) students, and an additional thirteen (13) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after their graduation effective date (e.g., in the NSLDS submission immediately following the graduation effective date, a status of full-time was incorrectly reported instead of withdrawn or graduated). ? For one (1) of the twenty two (22) students noted above, the incorrect Program-Level Enrollment Status was also reported to NSLDS after the date of determination of a Program-Level enrollment change. For four (4) of the twenty two (22) students noted above, the incorrect Program-Level Enrollment Status was reported to NSLDS after their graduation effective date. In total, we identified one or more of the instances of noncompliance described above in twenty two (22) of the forty (40) students selected for testing. As enrollment reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Due to the timing of the 2020 finding, management was unable to implement the corrective action plan in time for fiscal year 2021, resulting in the repeat finding. Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The Institute should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Additionally, the Institute should consider only reporting students with campus-level or program-level changes with each NSLDS submission, rather than the entire student roster.
Show full finding ▾Hide full finding ▴Finding 2021-002 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2020-2021 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. There are two categories of enrollment information; ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For nine (9) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (e.g., in the NSLDS submission immediately following the date the student was determined to have graduated, a status of full time was incorrectly reported instead). For eight (8) of these nine (9) students, and an additional thirteen (13) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after their graduation effective date (e.g., in the NSLDS submission immediately following the graduation effective date, a status of full-time was incorrectly reported instead of withdrawn or graduated). ? For one (1) of the twenty two (22) students noted above, the incorrect Program-Level Enrollment Status was also reported to NSLDS after the date of determination of a Program-Level enrollment change. For four (4) of the twenty two (22) students noted above, the incorrect Program-Level Enrollment Status was reported to NSLDS after their graduation effective date. In total, we identified one or more of the instances of noncompliance described above in twenty two (22) of the forty (40) students selected for testing. As enrollment reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Due to the timing of the 2020 finding, management was unable to implement the corrective action plan in time for fiscal year 2021, resulting in the repeat finding. Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The Institute should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Additionally, the Institute should consider only reporting students with campus-level or program-level changes with each NSLDS submission, rather than the entire student roster.
Modify End of Term and Graduate/Withdrawal files with respect to timing and who is included to NSC/NSLDS files to ensure timely reporting of change of status. End of term reporting will continue on existing schedule to capture student status at end of term. Graduating students will be reported on Graduate File 3 weeks after end of term. Subsequently, ONLY those students who are potential graduates and have not yet been cleared will be reported as ?Withdrawn? as a temporary status until they are cleared for graduation, upon which their status will be manually updated.
2020-002
Finding 2021-003 - Reporting ? Direct Loan and Pell Common Origination and Disbursement (?COD?) (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2020-2021 Criteria and Context: Pursuant to Federal Register Volume 82, Number 122, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (?COD?) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Context, Condition, Cause, and Effect: Of the forty (40) students selected for COD reporting testing, we identified the following instances of noncompliance: ? For one (1) student, their Fall 2020 Pell award was submitted to the COD 16 days after the award was disbursed to the student, which is outside of the required 15-day timeframe. ? For one (1) student, their Fall 2020 Unsubsidized, Subsidized, and Parent PLUS Loans were submitted to the COD 23 days after the awards were disbursed to the student, which is outside of the required 15-day timeframe. ? For one (1) student, their Fall 2020 and Summer 2020 Pell awards were submitted to the COD 27 days after the awards were disbursed to the student, which is outside of the required 15-day timeframe. As COD reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The Institute should review the effectiveness of its procedures governing the timely submission of disbursements to the COD system to ensure such records are submitted within the appropriate timeframe.
Show full finding ▾Hide full finding ▴Finding 2021-003 - Reporting ? Direct Loan and Pell Common Origination and Disbursement (?COD?) (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2020-2021 Criteria and Context: Pursuant to Federal Register Volume 82, Number 122, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (?COD?) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Context, Condition, Cause, and Effect: Of the forty (40) students selected for COD reporting testing, we identified the following instances of noncompliance: ? For one (1) student, their Fall 2020 Pell award was submitted to the COD 16 days after the award was disbursed to the student, which is outside of the required 15-day timeframe. ? For one (1) student, their Fall 2020 Unsubsidized, Subsidized, and Parent PLUS Loans were submitted to the COD 23 days after the awards were disbursed to the student, which is outside of the required 15-day timeframe. ? For one (1) student, their Fall 2020 and Summer 2020 Pell awards were submitted to the COD 27 days after the awards were disbursed to the student, which is outside of the required 15-day timeframe. As COD reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The Institute should review the effectiveness of its procedures governing the timely submission of disbursements to the COD system to ensure such records are submitted within the appropriate timeframe.
NYIT agrees with the three findings pertaining to COD disbursement reporting and will be instituting the following Corrective Action Plan to ensure that Direct Loan and PELL disbursement records are transmitted to COD within the 14-day timeframe allowed: NYIT Financial Aid office will increase the frequency of reconciliation report review. Several reconciliation reports generated from our Student Information System (PeopleSoft) will be reviewed on a weekly basis rather than the current bi-weekly timeframe. Additional staff members in the Office of Financial Aid will be trained to identify Direct Loan and PELL transactions that must be sent to COD. Training will include timely delivery and review of our reconciliation management reports. A senior-level review will be conducted weekly to ensure timely submission of all COD transactions. Any disbursement not sent to COD will be transmitted immediately and in compliance with timely reporting requirements.
FAC accepted this audit on November 22, 2021 — management decision was due May 22, 2022.
Finding 2020-001 ? Special Tests and Provisions ? Verification (Significant Deficiency) U.S. Department of Education ? Student Financial Assistance Cluster Federal Supplemental Education Opportunity Grant Program (84.007) Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2019-2020 Criteria and Context: Pursuant to 34 CFR Section 668.54(a), except as provided in paragraph (b) of 34 CFR Section 668.54, an institution must require an applicant whose Free Application for Federal Student Aid (?FAFSA?) FAFSA information is selected for verification by the Secretary, to verify the information specified by the Secretary pursuant to 34 CFR Section 668.56. Acceptable documentation for verification is further defined in 34 CFR Section 668.57, and specifically for the 2019-2020 award year, in Federal Register Volume 83, Number 60. From a selection of ninety (90) students, for which verification procedures were noted to be performed by the Institute, we identified three (3) students for which the information selected for verification did not agree with supporting records provided by the student. Condition, Cause, and Effect: Of the ninety (90) students selected for verification testing, we identified the following instances of noncompliance: ? For one (1) student, the number of household members and number of household members enrolled in college reported on her Institutional Student Information Record (?ISIR?) did not agree with the numbers reported on her signed student verification worksheet. The ISIR information was subsequently updated in PeopleSoft, the Institute?s financial aid system, and there was no change to the student?s expected family contribution (?EFC?). ? For one (1) student, the parents? U.S. income tax paid reported on the student?s ISIR did not agree with the U.S. income tax paid reported on her parents? tax return. The ISIR information was subsequently updated in PeopleSoft, and there was a $170 decrease to the student?s EFC. ? For one (1) student, the student education tax credits reported on the student?s ISIR did not agree with the student education tax credits reported on the student?s tax return. The ISIR information was subsequently updated in PeopleSoft, and there was no change to the student?s EFC. As verification procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The Institute should review its policies pertaining to verification and implement changes to enhance or clarify existing procedures in accordance with 34 CFR Part 668, Subpart E ? Verification and Updating of Student Aid Application Information. Further, additional training should be provided to staff to increase their awareness of necessary protocols for verifying an applicant?s FAFSA information.
Show full finding ▾Hide full finding ▴Finding 2020-001 ? Special Tests and Provisions ? Verification (Significant Deficiency) U.S. Department of Education ? Student Financial Assistance Cluster Federal Supplemental Education Opportunity Grant Program (84.007) Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2019-2020 Criteria and Context: Pursuant to 34 CFR Section 668.54(a), except as provided in paragraph (b) of 34 CFR Section 668.54, an institution must require an applicant whose Free Application for Federal Student Aid (?FAFSA?) FAFSA information is selected for verification by the Secretary, to verify the information specified by the Secretary pursuant to 34 CFR Section 668.56. Acceptable documentation for verification is further defined in 34 CFR Section 668.57, and specifically for the 2019-2020 award year, in Federal Register Volume 83, Number 60. From a selection of ninety (90) students, for which verification procedures were noted to be performed by the Institute, we identified three (3) students for which the information selected for verification did not agree with supporting records provided by the student. Condition, Cause, and Effect: Of the ninety (90) students selected for verification testing, we identified the following instances of noncompliance: ? For one (1) student, the number of household members and number of household members enrolled in college reported on her Institutional Student Information Record (?ISIR?) did not agree with the numbers reported on her signed student verification worksheet. The ISIR information was subsequently updated in PeopleSoft, the Institute?s financial aid system, and there was no change to the student?s expected family contribution (?EFC?). ? For one (1) student, the parents? U.S. income tax paid reported on the student?s ISIR did not agree with the U.S. income tax paid reported on her parents? tax return. The ISIR information was subsequently updated in PeopleSoft, and there was a $170 decrease to the student?s EFC. ? For one (1) student, the student education tax credits reported on the student?s ISIR did not agree with the student education tax credits reported on the student?s tax return. The ISIR information was subsequently updated in PeopleSoft, and there was no change to the student?s EFC. As verification procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The Institute should review its policies pertaining to verification and implement changes to enhance or clarify existing procedures in accordance with 34 CFR Part 668, Subpart E ? Verification and Updating of Student Aid Application Information. Further, additional training should be provided to staff to increase their awareness of necessary protocols for verifying an applicant?s FAFSA information.
Management is in agreement with the findings noted above, which were the result of staff errors or oversights in conducting verification analysis. At the time of the finding, quality assurance measures in the Office of Financial Aid included: 1) employees being trained in verification procedures and policies upon hire; and 2) employees having their verifications reviewed by a senior employee for the first two to four weeks following their training. Due to the volume of verifications each year, this oversight review was typically not continued beyond this two to four-week timeframe. Based upon the findings described above, the Office of Financial Aid has reviewed their current quality assurance program and is making adjustments to ensure all employees are more diligent when completing the verification process. Policies being implemented, which are set forth in more detail in the Corrective Action Plan, include: 1) additional senior level periodic reviews of completed verifications; 2) addition of a dual employee/peer review process; and 3) a requirement for all staff to utilize an internal verification checklist when completing the process and to keep a copy of the completed checklist in the student?s file. These policy modifications are feasible in light of the verification waiver announced by the U.S. Department of Education for the 2021-22 academic year. If the waiver is not extended past the next academic year, the Institute will re-assess its corrective actions to ensure they remain attainable.
Finding 2020-002 ? Special Tests and Provisions ? Enrollment Reporting (Material Weakness) U.S. Department of Education ? Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2019-2020 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. There are two categories of enrollment information; ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For twenty (20) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (e.g., in the NSLDS submission immediately following the date the student was determined to have graduated, a status of full-time was incorrectly reported instead). For seventeen (17) of these twenty (20) students, the incorrect Program-Level Enrollment Status was also reported to NSLDS after the date of determination of a Program-Level enrollment change. ? For one (1) student, the Campus-Level enrollment change was not reported timely (within 60 days) to NSLDS. [This one (1) student was also included in the twenty (20) students identified in the first bullet point above]. ? For eight (8) students, the Program Begin Date, defined as the date the student first began attending the program being reported, was incorrectly reported to NSLDS. [Three (3) of these students were also included in twenty (20) students identified in the first bullet point above]. In total, we identified one or more of the instances of noncompliance described above in twenty-five (25) of the forty (40) students selected for testing. As enrollment reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The Institute should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Additionally, the Institute should consider only reporting students with campus-level or program-level changes with each NSLDS submission, rather than the entire student roster.
Show full finding ▾Hide full finding ▴Finding 2020-002 ? Special Tests and Provisions ? Enrollment Reporting (Material Weakness) U.S. Department of Education ? Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Student Loan Program (84.268) Federal Award Year: 2019-2020 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. There are two categories of enrollment information; ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 30 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845-0002) mailboxes sent by ED via the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Of the forty (40) students selected for enrollment reporting testing, we identified the following instances of noncompliance: ? For twenty (20) students, the incorrect Campus-Level Enrollment Status was reported to NSLDS after the date of determination of a Campus-Level enrollment change (e.g., in the NSLDS submission immediately following the date the student was determined to have graduated, a status of full-time was incorrectly reported instead). For seventeen (17) of these twenty (20) students, the incorrect Program-Level Enrollment Status was also reported to NSLDS after the date of determination of a Program-Level enrollment change. ? For one (1) student, the Campus-Level enrollment change was not reported timely (within 60 days) to NSLDS. [This one (1) student was also included in the twenty (20) students identified in the first bullet point above]. ? For eight (8) students, the Program Begin Date, defined as the date the student first began attending the program being reported, was incorrectly reported to NSLDS. [Three (3) of these students were also included in twenty (20) students identified in the first bullet point above]. In total, we identified one or more of the instances of noncompliance described above in twenty-five (25) of the forty (40) students selected for testing. As enrollment reporting procedures were not performed properly for the students identified above, the Institute did not comply with the aforementioned regulations. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The Institute should review its policies pertaining to enrollment reporting and implement changes to ensure that student status transmission reports are submitted timely and accurately to the NSLDS throughout the entire award year. Additionally, the Institute should consider only reporting students with campus-level or program-level changes with each NSLDS submission, rather than the entire student roster.
I. Campus-Level and Program-Level Enrollment Statuses Not Reported Accurately Management Response and Corrections Made Management agrees in part and disagrees in part with this portion of the finding. The Institute was timely in its reporting of these students? status changes ? that is, the graduation and withdrawal statuses were updated within 60 days of the Institute?s notice of the student?s change in status. However, in addition to that timeliness requirement, the auditors also tested the accuracy of each enrollment report submitted by the Institute. So, even though the students? statuses were updated within 60 days of determination, there were enrollment reports submitted between the time the student completed the requirements and the time the Institute updated the records. This is in part because the Institute follows its third-party servicer recommendations from the National Student Clearinghouse (?NSC?) to submit at least monthly enrollment reports for NSLDS updating. The auditors find this to be ?inaccurate? reporting, as the report immediately following the triggering event (graduation or withdrawal) does not yet reflect that status change. i. The Institute agrees with this logic for the 3 student withdrawals and has made appropriate corrections: The Institute acknowledges that students who withdraw or whose degree requirements have been verified for graduation should be included in the next-submitted enrollment report. To avoid this error in the future, Registrar has contacted NSC to confirm and update proper reporting for these instances. Registrar will now report these students as withdrawn (?W?) in the ?end of term? submission, not waiting for faculty attendance and grades to arrive for the just-completed term, as they did previously. This means that Registrar will have to re-assess the student records once attendance and grades for the reported term are received, and any changes to a student?s enrollment status for the just-completed term will have to be corrected via a subsequent manual update to NSC. ii. The Institute disagrees with the finding in regard to students who have applied for graduation, but whose degrees have not yet been verified by the Institute: The Institute?s prior practice was based upon NSLDS guidance that students? enrollment for summer does not need to be reported if there is reason to believe the student may return in the fall, since summer is not a compulsory term. The auditors, however, have asserted that the Institute should not have left the students as full-time (?FT?) status because they were eligible for or had applied for graduation. But, until the degree verification process for the student is complete, the Registrar would not know if that student might be returning in the fall to complete requirements. Therefore, the Institute does not believe that NSLDS requires it to submit an interim withdrawal report for students that have applied for graduation but have not yet been verified to have met the degree requirements. We read NSLDS guidance as being suggestive of reporting the interim withdrawal for these students, and not a mandate, as the auditors found. However, to ensure no future findings or even temporary student loan impact, Registrar has updated its practices to include an interim report of all graduate-eligible students, assigning them a withdrawn status immediately following the ?end of term? report. For example, in the Spring 2021 reporting, Registrar submitted its ?end of term? file on June 3, 2021, and the following day, June 4, submitted the interim W file with all graduate-eligible students. Then, after the degree verification process is complete during the summer months, Registrar will batch update all interim W?s to graduated status. These processes are being followed for both campus and program level reporting. This will ensure indisputably accurate and timely status updates to NSLDS at all levels. II. Campus-Level Enrollment Change Not Reported Timely Management Response and Corrections Made Because the student?s status for the summer was as a non-matriculated student, management concurs that the campus level report should have been marked as graduated due to her graduation in the spring. To address this error, the Registrar has initiated a stop to a process called ?term activate,? meaning students eligible for graduation may no longer self-enroll in summer (or other future term) courses without first meeting with Academic Advising or Registrar to ensure proper enrollment. Also, the Registrar will make sure to differentiate reporting based on whether additional courses are part of separate, degree-eligible program. This distinction in whether a student is returning for a degree-granting program versus returning to complete any additional course(s) was not clear to the Registrar until this particular student was identified. III. Incorrect Program Begin Date Management Response and Corrections Made Management acknowledges the program begin date errors which occurred due to our student information system, Oracle Peoplesoft, pulling the incorrect data field for ?program begin date? in these situations, including leaves of absences and changes in majors. Oracle has been programmed to report ?program begin date? on the date a student returns from leave of absence, is readmitted to a program after withdrawal, or returns to FT status. The Registrar notified Oracle of the discrepancy, and they responded that they are working on an update with their programming development team. Given that this systemic fix by Oracle will likely take a great deal of time, the Institute?s Information Technology team has worked with the Registrar to create a workaround solution, pending Oracle?s update. The IT team created a solution to pull the program begin date when a student first enrolled in the program. If a student takes a leave of absence or is readmitted to the program, then the solution will pull the program begin date correctly. If a student changes their program but then subsequently returns to the initial program, then the solution will report the initial program begin date. The Registrar is currently completing testing of the fix and working on corrective submissions for updating prior program begin date errors (detailed in Corrective Action Plan). To correct the issue identified in Cycle courses, the Registrar will differentiate dates for students starting courses in Cycle B or D (that do not begin the same date as the full semester). This fix required additional programming by the IT department, which has been completed and is currently being tested by the Registrar. The solution delivered by IT identifies students enrolled in Cycles B or D and adjusts their program begin date to align with the Cycles B or D start date. This feature is unique to the Institute and most likely will not be delivered by Oracle. The Registrar and IT are also working on updating programming for Summer II program begin dates, which the Institute discovered as another potential instance where the program begin date may be different than the Summer I (full summer) term.
FAC accepted this audit on May 7, 2020 — management decision was due November 7, 2020.
FAC accepted this audit on May 29, 2019 — management decision was due November 29, 2019.
FAC accepted this audit on May 23, 2018 — management decision was due November 23, 2018.
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
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