Virginia University of Integrative MedicineNon-Profit

Federal Program: 84.268 Criteria: Under 34 CFR 685.309, institutions are required to report enrollment information in a timely manner – at a minimum, institutions are required to certify enrollment every 60 days or every other month. Condition: For the year under audit, one of the students selected for testing had a reportable change in enrollment status (from less than half time to deceased) the end of Summer 2023 term yet the University did not report this change until May 2024. Cause: This was a unique circumstance and the University’s staff was unsure how to respond. Effect: The University did not comply with the time reporting requirement under 34 CFR 685.309. Context: This circumstance involved one student out of a sample of three for a population of 29 for those students having a reportable change in enrollment status. Recommendation: The University should bolster its enrollment reporting procedures to address unusual circumstances for changes in enrollment which includes bringing the matter to the attention of senior management and to consult with the third-party servicer within the prescribed 60 days. Management’s View: See Corrective Action Plan.

Federal Program: 84.268 Criteria: Under 34 CFR 668.164(h)(2), institutions must pay the resulting credit balance directly to the student or parent borrower within 14 days after 1) the first day of class of a payment period if the credit balance occurred on or before that day, or 2) the balance occurred if occurring after the first day of class. Condition: For the year under audit, the University was one day late in paying a credit balance to the student. Cause: There was a delay by senior management in authorizing the wire transfer (the request had been processed on time). Effect: The University did not comply with 34 CFR 668.164(h)(2). Context: This circumstance involved one student out of a sample of 23 for a population of 227. Recommendation: The University should bolster its processing procedures to help ensure delays are monitored and, if necessary, have a second member of senior management available to authorize these transfers. Management’s View: See Corrective Action Plan.

Federal Program: 84.268 Criteria: Under 34 CFR 668.164(l)(3), checks sent to students that are not returned to the institution (i.e., not cashed) must be returned to the Secretary no later than 240 days after the date the checks were issued. Condition: For the year under audit, the University reported $17,809 of outstanding (uncleared) refund checks to students in excess of 240 days. Cause: Management was unaware of the 240 day requirement. Effect: The University did not comply with 34 CFR 668.164(l)(3). Context: N/A. Recommendation: The University should implement a policy that future uncleared student checks are monitored for compliance with the 240 day requirement and one or more procedures that provides reasonable assurance of complying with this policy (possibly as part of reviewing bank reconciliations). Also, all checks older than 240 days should be sent (returned) to the Secretary. Management’s View: See Corrective Action Plan.