Nazareth UniversityHigher Education

Criteria – Institutions are required, for each student whose application is selected by the U.S. Department of Education (DOE), to verify the information required for the verification tracking group to which the applicant is assigned. Condition – For one out of 40 students selected for testing, the University did not perform the required verification procedures. Cause – The University was required to verify the student’s and parents’ AGI, income taxes paid, additional income, and family size and family members attending college. Per the July 8, 2022 Federal Register, income information for tax filers is not required to be separately verified if the school identified the information as being obtained using the Internal Revenue System Data Retrieval Tool (IRS DRT) and the information was not changed. This student’s Institutional Student Information Record (ISIR) indicated that the student’s parents did not use the IRS DRT; however, the parents incorrectly indicated on their verification worksheet that they did use the IRS DRT. Although the parents reported incorrect information, the University is responsible for ensuring that the IRS DRT was used. As a result, the University failed to verify the required parents’ income information. Effect – The University was not in compliance with the DOE’s requirements for verification. Recommendation – We recommend that the University develop policies and procedures surrounding verification information that is reported on the ISIR in order to ensure verification is completed accurately. View of Responsible Officials – We agree with the auditor’s finding as set forth above. The University has experienced turnover in recent years in the financial aid department. The University provided additional training to financial aid staff to ensure review of student information received is completed accurately and agrees with the information provided on the student’s ISIR.

Criteria – According to federal regulations, institutions are required to calculate and disburse Pell and Teacher Education Assistance for College and Higher Education (TEACH) Grants to eligible students based on specific eligibility criteria. Condition – The University awarded more than the maximum allowed Pell Grant to one student, and more than the maximum allowed TEACH Grant to two students, from the sample of 40 students that were selected for testing. Cause – Human error resulted in the University over-awarding Pell and TEACH grants. Effect – The University did not properly disburse Pell or TEACH Grants, resulting in over awarding the affected students. Recommendation – We recommend that the University provide training to staff on identifying and resolving registration changes and exceeded annual grant limits impacting Pell and TEACH disbursements. We also recommend that the University enhance and monitor the effectiveness of controls to ensure timely and accurate adjustments to students’ disbursements in compliance with federal requirements. View of Responsible Officials – We agree with the auditor’s finding as set forth above. Due to turnover in the financial aid department, there was an incorrect understanding of the maximum award process. We have updated the University’s policies and procedures to ensure they are compliant with Title IV requirements and will be assigning this responsibility to a new employee. The University has refunded, through Common Origination and Disbursement, any federal funding associated with the over-awards as noted in this finding.

Criteria – After a student withdraws and is determined to not have earned 100% of their Title IV funds, institutions are required to return the unearned portion of Title IV funds to DOE within 45 days of the institution determining that the student had withdrawn. Condition – Out of four withdrawals selected for testing, the University did not return one student’s portion of unearned Title IV funds until 56 days after it determined that the student had withdrawn. Cause – The University did not have effective controls in place to ensure that Title IV funds were returned within the 45 day window. Effect – The University was not in compliance with the DOE’s requirements for returning funds to the DOE. Recommendation – We recommend that the University assess and ensure that there are adequate resources and training available to handle Title IV fund returns timely. Additionally, we recommend the University develop policies and procedures to ensure timely processing of refunds View of Responsible Officials – We agree with the auditor’s finding as set forth above. The University has experienced turnover in recent years in the financial aid department. This responsibility has been assigned to a new individual who has the necessary training and experience to ensure that Return to Title IV refunds are completed in the required timeframe.