EIN: 231352688
UEI: EYNYSU6L8ZX6
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 27, 2025. 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 August 27, 2025 (364 days ago).
What is a management decision? →Findings and Questioned Costs Relating to Federal Awards Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 and 84.063 Federal Award Year: Funding periods between June 1, 2023 through May 31, 2024 Compliance Requirement: Enrollment Reporting Finding Type: Noncompliance and Significant Deficiency Criteria: 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition, including perspective For seven out of the 25 students sampled for testing the timeliness and accuracy of the University’s reporting of student enrollment status change to the National Student Loan Data System (NSLDS), the changes in their enrollment status were not reported to NSLDS. These seven students were part of the University’s May 2024 graduating class of 307 students from the College of Liberal Arts and Sciences that were not reported as required to NSLDS. A total of 2,272 students graduated from the University in May 2024. Cause and Effect The University did not have sufficient controls in place to ensure complete and accurate reporting of all student enrollment status changes to NSLDS. Consequently, the June 2024 transmission to NSLDS excluded students who graduated from the College of Liberal Arts and Sciences. In September 2024, the National Student Clearinghouse (NSC), on behalf of the University, updated these students’ status to “withdrawn” for reporting to the NSLDS because they were not included in the University’s active Fall semester roster. This deficiency could affect the timing of these students’ transition into federal loan repayment, however, both the graduated and withdrawn status trigger the student entering into repayment. Questioned Costs No question costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend the University enhance its current policies and procedures to ensure that changes to students’ enrollment status is accurately reflected in the underlying records prior to being transmitted. Views of Responsible Officials Villanova University accepts this finding. During the year, there was turnover at the University and we acknowledge the training of new staff is always a priority for the University. Appropriate training and new internal control processes have been implemented. The department has implemented a new graduate only submission file to be transmitted to the NSC at the end of May and another at the end of June. In addition, the University has created a Graduation Audit Report to verify the change in status for students who graduated and a final validation with the Senior Assistant Registrar for Student History to confirm accuracy of student status.
Show full finding ▾Hide full finding ▴Findings and Questioned Costs Relating to Federal Awards Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 and 84.063 Federal Award Year: Funding periods between June 1, 2023 through May 31, 2024 Compliance Requirement: Enrollment Reporting Finding Type: Noncompliance and Significant Deficiency Criteria: 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition, including perspective For seven out of the 25 students sampled for testing the timeliness and accuracy of the University’s reporting of student enrollment status change to the National Student Loan Data System (NSLDS), the changes in their enrollment status were not reported to NSLDS. These seven students were part of the University’s May 2024 graduating class of 307 students from the College of Liberal Arts and Sciences that were not reported as required to NSLDS. A total of 2,272 students graduated from the University in May 2024. Cause and Effect The University did not have sufficient controls in place to ensure complete and accurate reporting of all student enrollment status changes to NSLDS. Consequently, the June 2024 transmission to NSLDS excluded students who graduated from the College of Liberal Arts and Sciences. In September 2024, the National Student Clearinghouse (NSC), on behalf of the University, updated these students’ status to “withdrawn” for reporting to the NSLDS because they were not included in the University’s active Fall semester roster. This deficiency could affect the timing of these students’ transition into federal loan repayment, however, both the graduated and withdrawn status trigger the student entering into repayment. Questioned Costs No question costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend the University enhance its current policies and procedures to ensure that changes to students’ enrollment status is accurately reflected in the underlying records prior to being transmitted. Views of Responsible Officials Villanova University accepts this finding. During the year, there was turnover at the University and we acknowledge the training of new staff is always a priority for the University. Appropriate training and new internal control processes have been implemented. The department has implemented a new graduate only submission file to be transmitted to the NSC at the end of May and another at the end of June. In addition, the University has created a Graduation Audit Report to verify the change in status for students who graduated and a final validation with the Senior Assistant Registrar for Student History to confirm accuracy of student status.
Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error have been implemented. The department has created a submission file consisting of new graduates only to be transmitted to the National Student Clearinghouse at the end of May and another at the end of June to identify any additional students to report. In addition, the University has created a Graduation Audit Report to be used internally to verify the change in status for students who graduated, and a final validation check performed by the Senior Assistant Registrar for Student History to confirm accuracy of student status. Name of contact person: Susan Morgan, Director of Technical Student Systems, Registrars Office Anticipated Completion date: May 2025 in conjunction with the next submission of graduation files
FAC accepted this audit on February 28, 2024 — management decision was due August 28, 2024.
Finding 2023-001 –Special Tests and Provisions Grantor(s): Department of Education Program: Student Financial Aid Cluster Assistance Listing #: Various Award Title: Student Financial Aid Cluster Award Year: 6/2022- 5/2023 Award #: N/A Pass-through #: Not applicable Criteria Per the 2022 OMB Compliance Supplement, at the time an institution makes a disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). Additionally, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Also, where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution is required to provide the credit balance to the student within 14 days of the date the balance was created (34 CFR 668.164(h)(2)). An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition Disbursements to or on behalf of students Through testing disbursements to or on behalf of students enrolled at the University, it was noted that 2 students out of a sample of 25 did not have evidence that the student file was reviewed to ensure all disbursement requirements were satisfied prior to the first disbursement to the student. For one of these students, the date of review was subsequent to the date of the first disbursement to the student. For the second student, there was no date of review. Additionally, it was noted that 3 students out of the same sample of 25 did not receive notification of their disbursements for the Fall 2022 academic term. The students received disbursements on August 16th, 12th, and 14th, respectively, and did not receive notification of these disbursements. Through testing disbursements to or on behalf of students enrolled at the University, it was noted that 1 student out of the same sample of 25 had a credit balance that was not refunded within the required 14-day period. For this particular student, the credit balance was created on January 13, 2023 and refunded to the student on February 2, 2023, which is 20 days later. Verification Through testing of verification, 1 student out of a sample of 25 was not verified even though the student was selected for verification. Cause Disbursements to or on behalf of students The cause of the finding related to the 2 students without evidence of review to ensure all disbursement requirements were met prior to the first disbursement to the student was due to lack of recording the review within the student account. The cause of the finding related to the 3 students who did not receive notification of their disbursements for the Fall 2022 academic term was a University system error during the period of August 9, 2022 through August 16, 2022 which sent required disbursement notifications to only those students with last names beginning with letters A-Po. All other students with last names outside this range did not receive the required notifications during this time period. The cause of the credit balance refund finding is due to inadequate review when reviewing the report showing all students with credit balances and the date on which the credit balance was created. Verification The cause of the finding was inadequate review of the student file as management incorrectly thought the student was included in verification type v1, which had waived verification requirements during FY2023. Effect Disbursements to or on behalf of students The students could have received an inappropriate amount of financial aid as the review of disbursement requirements was not performed prior to disbursement. For these two students, subsequent review performed by management revealed that they met all disbursement requirements. The students did not receive timely notification that their financial aid was disbursed. The student received their refund later than the deadline required by the regulations. Verification The student could have received an inappropriate amount of financial aid as they were flagged for verification that ultimately was not performed. Questioned Costs None as students were eligible for the aid they received, and the aid was disbursed at the correct amount. Recommendation Management should enhance their monitoring controls over student disbursements to ensure the student has met disbursement requirements prior to first disbursement and students are notified about their disbursements. The enhanced control should include a second level of review to ensure files are appropriately reviewed and students are appropriately notified prior to disbursement. Management should also enhance their monitoring control over credit balance refunds to ensure refunds are made within the required timeframe. The enhanced control should include updating \the report used to monitor the aging of student credit balances. Verification Management should enhance its monitoring control for review of verification procedures being completed. The enhanced control should include a second level of review to ensure that all students selected for verification procedures have been verified accurately and timely.
Show full finding ▾Hide full finding ▴Finding 2023-001 –Special Tests and Provisions Grantor(s): Department of Education Program: Student Financial Aid Cluster Assistance Listing #: Various Award Title: Student Financial Aid Cluster Award Year: 6/2022- 5/2023 Award #: N/A Pass-through #: Not applicable Criteria Per the 2022 OMB Compliance Supplement, at the time an institution makes a disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). Additionally, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Also, where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution is required to provide the credit balance to the student within 14 days of the date the balance was created (34 CFR 668.164(h)(2)). An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition Disbursements to or on behalf of students Through testing disbursements to or on behalf of students enrolled at the University, it was noted that 2 students out of a sample of 25 did not have evidence that the student file was reviewed to ensure all disbursement requirements were satisfied prior to the first disbursement to the student. For one of these students, the date of review was subsequent to the date of the first disbursement to the student. For the second student, there was no date of review. Additionally, it was noted that 3 students out of the same sample of 25 did not receive notification of their disbursements for the Fall 2022 academic term. The students received disbursements on August 16th, 12th, and 14th, respectively, and did not receive notification of these disbursements. Through testing disbursements to or on behalf of students enrolled at the University, it was noted that 1 student out of the same sample of 25 had a credit balance that was not refunded within the required 14-day period. For this particular student, the credit balance was created on January 13, 2023 and refunded to the student on February 2, 2023, which is 20 days later. Verification Through testing of verification, 1 student out of a sample of 25 was not verified even though the student was selected for verification. Cause Disbursements to or on behalf of students The cause of the finding related to the 2 students without evidence of review to ensure all disbursement requirements were met prior to the first disbursement to the student was due to lack of recording the review within the student account. The cause of the finding related to the 3 students who did not receive notification of their disbursements for the Fall 2022 academic term was a University system error during the period of August 9, 2022 through August 16, 2022 which sent required disbursement notifications to only those students with last names beginning with letters A-Po. All other students with last names outside this range did not receive the required notifications during this time period. The cause of the credit balance refund finding is due to inadequate review when reviewing the report showing all students with credit balances and the date on which the credit balance was created. Verification The cause of the finding was inadequate review of the student file as management incorrectly thought the student was included in verification type v1, which had waived verification requirements during FY2023. Effect Disbursements to or on behalf of students The students could have received an inappropriate amount of financial aid as the review of disbursement requirements was not performed prior to disbursement. For these two students, subsequent review performed by management revealed that they met all disbursement requirements. The students did not receive timely notification that their financial aid was disbursed. The student received their refund later than the deadline required by the regulations. Verification The student could have received an inappropriate amount of financial aid as they were flagged for verification that ultimately was not performed. Questioned Costs None as students were eligible for the aid they received, and the aid was disbursed at the correct amount. Recommendation Management should enhance their monitoring controls over student disbursements to ensure the student has met disbursement requirements prior to first disbursement and students are notified about their disbursements. The enhanced control should include a second level of review to ensure files are appropriately reviewed and students are appropriately notified prior to disbursement. Management should also enhance their monitoring control over credit balance refunds to ensure refunds are made within the required timeframe. The enhanced control should include updating \the report used to monitor the aging of student credit balances. Verification Management should enhance its monitoring control for review of verification procedures being completed. The enhanced control should include a second level of review to ensure that all students selected for verification procedures have been verified accurately and timely.
The University agrees with this finding. As a result, the University has taken the following actions to be executed in FY24: Verification The University agrees with this finding. The Office of Financial Assistance has created additional reporting to confirm verification is completed for all required verifications. These reports will be run weekly and reviewed by a financial aid counselor, to confirm all V4 and V5 are completed and not waived. Disbursement The University agrees with this finding. The Office of Financial Assistance has made additional disbursement monitoring checks within the Banner system. These checks will stop a fund from disbursing unless the required documents have been satisfied in the system. These will be reviewed weekly on disbursement error reports shared with the office. 14-day refund Period The University agrees with this finding. The Bursar's Office implemented the following procedure when the finding was identified: To avoid such errors in the future and to ensure that the Bursar's Office adheres to the 14-day requirement, the Bursar's Office has established a procedure whereby the Refund Specialist must complete a federal refund report and provide it to the Associate Bursar for sign-off before running a subsequent report. This will ensure that refunds are not overlooked due to staff not processing a report in its entirety. Notification The University agrees with this finding. This does appear to have been an error with the job run on the identified sample day and not a human error. The Bursar's Office is reviewing each notification run output to ensure all notifications are produced. If there is any issue, the Bursar's Office will ensure any unsent e-mails are sent in the proper time.
FAC accepted this audit on February 27, 2023 — management decision was due August 27, 2023.
Finding 2022-001 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268 Title: Federal Direct Student Loan Program Award Year: 6/1/2021 ? 5/31/2022 Criteria NSLDS Enrollment Reporting Guide 1.4 ? At a minimum, schools are required to certify enrollment for all those who are included on your roster file (and) Title IV aid recipients at least every two months and within 15 days of the date that NSLDS sends a roster file to the school or its third-party service provider. 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Unless expected to submit its next updated enrollment report to the Secretary within the next 60 days, the University is required to notify National Student Loan Data System (NSLDS) within 30 days of discovering that a student left the University. Of the 25 students selected for testing, three were reported to NSLDS more than 60 days after the student had left the University, ranging between 69 and 98 days with an average of 79 days. Cause The University did not implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Effect For the three students, the change in status was not reported timely, as defined in the criteria above. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the University implement a formalized review process with the Clearinghouse and National Student Loan Data System (NSLDS) to ensure timely reporting of student status changes. Management?s Views and Corrective Action Plan Following these findings are management?s views and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2022-001 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268 Title: Federal Direct Student Loan Program Award Year: 6/1/2021 ? 5/31/2022 Criteria NSLDS Enrollment Reporting Guide 1.4 ? At a minimum, schools are required to certify enrollment for all those who are included on your roster file (and) Title IV aid recipients at least every two months and within 15 days of the date that NSLDS sends a roster file to the school or its third-party service provider. 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Unless expected to submit its next updated enrollment report to the Secretary within the next 60 days, the University is required to notify National Student Loan Data System (NSLDS) within 30 days of discovering that a student left the University. Of the 25 students selected for testing, three were reported to NSLDS more than 60 days after the student had left the University, ranging between 69 and 98 days with an average of 79 days. Cause The University did not implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Effect For the three students, the change in status was not reported timely, as defined in the criteria above. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the University implement a formalized review process with the Clearinghouse and National Student Loan Data System (NSLDS) to ensure timely reporting of student status changes. Management?s Views and Corrective Action Plan Following these findings are management?s views and corrective action plan.
Enrollment Reporting - Executed in FY23 The University agrees with this finding. As a result, the University has taken the following action: The Office of the Registrar has adjusted their processes so that students who are on a LOA will continue to be in an AS- Active Student status for 180 days after their LOA and will have an active enrollment status (WL - LOA Withdrawn (NSC)) on the student registration form to ensure they are sent to the National Student Clearinghouse in a timely manner. The Office of the Registrar has also adjusted their processes so that students withdrawing at the end of a semester will have an active enrollment status (WE - Withdrawn EOT) on their student registration form to ensure they are sent to the National Student Clearinghouse in a timely manner.
FAC accepted this audit on June 28, 2021 — management decision was due December 28, 2021.
Finding 2020-001 Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268, 84.063 Title: Federal Direct Student Loan Program, Federal Pell Grant Program Award Year: 6/1/2019 ? 5/31/2020 Criteria 34 CFR section 685.102, 685.301, 685.303 and 690.83 ? ?Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 payment methods (see Federal Register Volume 84, Number 212, November 1, 2019). The disbursement record reports the actual disbursement date and the amount of the disbursement. ? Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. 2019-2020 COD Technical Reference, Volume II ? ?Schools must report disbursements within 15 days according to the regulations.? Condition Of 25 students selected for testing the reported date, amount of disbursement and timeliness of reporting to COD for Pell awards, 5 of the 25 students selected for testing were reported subsequent to the 15-day reporting regulation noted above. Cause The University did not implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Effect The student?s COD records were not reported timely. Questioned Costs None. Recommendation We recommend management implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Management's View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-001 Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268, 84.063 Title: Federal Direct Student Loan Program, Federal Pell Grant Program Award Year: 6/1/2019 ? 5/31/2020 Criteria 34 CFR section 685.102, 685.301, 685.303 and 690.83 ? ?Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 payment methods (see Federal Register Volume 84, Number 212, November 1, 2019). The disbursement record reports the actual disbursement date and the amount of the disbursement. ? Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. 2019-2020 COD Technical Reference, Volume II ? ?Schools must report disbursements within 15 days according to the regulations.? Condition Of 25 students selected for testing the reported date, amount of disbursement and timeliness of reporting to COD for Pell awards, 5 of the 25 students selected for testing were reported subsequent to the 15-day reporting regulation noted above. Cause The University did not implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Effect The student?s COD records were not reported timely. Questioned Costs None. Recommendation We recommend management implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Management's View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Management?s Response Finding 2020-001: Reporting The University agrees with this finding. As a result, the University has taken the following action: The Office of Financial Assistance has implemented a monthly Pell reconciliation process, along with reviewed and updated policies and procedures. Previously, only one person was assigned with the responsibility of Pell and became ill during the time of the above findings. The Office of Financial Assistance has since set up two back-ups in the event of illness, change of employment, etc. Weekly files will be sent to COD to report new disbursements. The following day, the response file from COD will be reviewed and checked for possible rejects. In the event of a reject, the student information will be updated and resent to COD to be accepted. This process will allow the University to meet the 15-day reporting requirement. In addition, monthly reconciliation will be completed by the Pell team and reported to the Controller?s Office for necessary G5 draws.
Finding 2020-002 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268 Title: Federal Direct Student Loan Program Award Year: 6/1/2019 ? 5/31/2020 Criteria NSLDS Enrollment Reporting Guide 1.5 ? At a minimum, schools are required to certify enrollment for all those who are included on your roster file (and) Title IV aid recipients at least every two months and within 15 days of the date that NSLDS sends a roster file to the school or its third-party service provider. 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Unless expected to submit its next updated enrollment report to the Secretary within the next 60 days, the University is required to notify National Student Loan Data System (NSLDS) within 30 days of discovering that a student left the University. Of the 25 students selected for testing, two were reported to NSLDS more than 60 days after the student had left the University, ranging between 66 and 80 days with an average of 73 days. Cause The University did not implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Effect For the two students, the change in status was not reported timely, as defined in the criteria above. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the University implement a formalized review process with the Clearinghouse and National Student Loan Data System (NSLDS) to ensure timely reporting of student status changes. Management?s Views and Corrective Action Plan Following these findings are management?s views and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-002 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268 Title: Federal Direct Student Loan Program Award Year: 6/1/2019 ? 5/31/2020 Criteria NSLDS Enrollment Reporting Guide 1.5 ? At a minimum, schools are required to certify enrollment for all those who are included on your roster file (and) Title IV aid recipients at least every two months and within 15 days of the date that NSLDS sends a roster file to the school or its third-party service provider. 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition Unless expected to submit its next updated enrollment report to the Secretary within the next 60 days, the University is required to notify National Student Loan Data System (NSLDS) within 30 days of discovering that a student left the University. Of the 25 students selected for testing, two were reported to NSLDS more than 60 days after the student had left the University, ranging between 66 and 80 days with an average of 73 days. Cause The University did not implement reconciliation and review policies and procedures to ensure compliance with the criteria mentioned above. Effect For the two students, the change in status was not reported timely, as defined in the criteria above. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the University implement a formalized review process with the Clearinghouse and National Student Loan Data System (NSLDS) to ensure timely reporting of student status changes. Management?s Views and Corrective Action Plan Following these findings are management?s views and corrective action plan.
Management?s Response Finding 2020-002: Enrollment Reporting The University agrees with this finding. As a result, the University has taken the following action: The Office of the Registrar has created queries to audit all status changes as a result of a leave of absence or withdrawal so that these changes are captured appropriately in the University?s database to ensure accurate reporting to the National Student Clearinghouse. This monthly reconciliation procedure will alert staff to these students so that the department can check that the inactivation/withdrawal process has been handled correctly and the withdrawal status is reported within the mandatory timeframe.
FAC accepted this audit on January 20, 2020 — management decision was due July 20, 2020.
Finding 2019-001 Verification Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268, 84.063 Title: Federal Direct Student Loan Program, Federal Pell Grant Program Award Year: 6/2018 ? 5/2019 Criteria 34 CFR 668.57: If an applicant is selected to verify any of the following information, an institution must obtain the specified documentation. (c) Number of family household members enrolled in eligible postsecondary institutions. (1) An institution must require an applicant selected for verification of the number of household members in the applicant?s family enrolled on at least a half-time basis in eligible postsecondary institutions to submit a statement signed by both the applicant and one of the applicant?s parents, if the applicant is a dependent student, or by only the applicant if the applicant is an independent student, listing? (i) The name of each family member who is or will be attending an eligible postsecondary educational institution as at least a half-time student in the award year; (ii) The age of each student; and (iii) The name of the institution that each student is or will be attending. 34 CFR Section 668.59 (a) - For the subsidized student financial assistance programs, if an applicant?s FAFSA information changes as a result of verification, the applicant or the institution must submit to the Secretary any changes to? (1) A nondollar item; or (2) A single dollar item of $25 or more 34 CFR Section 668.59 (b) - For the Federal Pell Grant Program, if an applicant?s FAFSA information changes as a result of verification, an institution must? (1) Recalculate the applicant?s Federal Pell Grant on the basis of the EFC on the corrected valid SAR or valid ISIR; and (2)(i) Disburse any additional funds under that award only if the institution receives a corrected valid SAR or valid ISIR for the applicant and only to the extent that additional funds are payable based on the recalculation; (ii) Comply with the procedures specified in ?668.61 for an interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced; or? (iii) Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced. 34 CFR Section 668.59 (c) - For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an applicant?s FAFSA information changes as a result of verification, the institution must? (1) Adjust the applicant?s financial aid package on the basis of the EFC on the corrected valid SAR or valid ISIR; and (2)(i) Comply with the procedures specified in ?668.61 for an interim disbursement if, as a result of verification, the financial aid package must be reduced; (ii) Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an FSEOG overpayment that is not the result of an interim disbursement if, as a result of verification, the financial aid package must be reduced; and (iii) Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan excess loan proceeds that are not the result of an interim disbursement if, as a result of verification, the financial aid package must be reduced. Condition Of 25 selections tested for verification procedures, two instances were noted in which the number of family household members enrolled in eligible postsecondary institutions per the ISIR did not agree to the amount included on the subsequently obtained verification form. In these instances, management did not update the information prior to awarding and disbursing Federal Aid to the students. Cause Management calculated aid eligibility based on the ISIR data. The students then submitted the verification forms after completion of ISIR with a different number of family household members enrolled in eligible postsecondary institutions, which was not caught timely by management in the standard verification procedures. Effect The calculation of the students? eligibility for Federal Aid was determined with partially incorrect data. One student received additional institutional aid in lieu of additional Federal aid. Questioned Costs None. Recommendation Management should enhance the monitoring control in place for review of verification procedures being completed timely. The enhanced control should include a second level of review to ensure that all students selected for verification procedures have been verified accurately and timely. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-001 Verification Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.268, 84.063 Title: Federal Direct Student Loan Program, Federal Pell Grant Program Award Year: 6/2018 ? 5/2019 Criteria 34 CFR 668.57: If an applicant is selected to verify any of the following information, an institution must obtain the specified documentation. (c) Number of family household members enrolled in eligible postsecondary institutions. (1) An institution must require an applicant selected for verification of the number of household members in the applicant?s family enrolled on at least a half-time basis in eligible postsecondary institutions to submit a statement signed by both the applicant and one of the applicant?s parents, if the applicant is a dependent student, or by only the applicant if the applicant is an independent student, listing? (i) The name of each family member who is or will be attending an eligible postsecondary educational institution as at least a half-time student in the award year; (ii) The age of each student; and (iii) The name of the institution that each student is or will be attending. 34 CFR Section 668.59 (a) - For the subsidized student financial assistance programs, if an applicant?s FAFSA information changes as a result of verification, the applicant or the institution must submit to the Secretary any changes to? (1) A nondollar item; or (2) A single dollar item of $25 or more 34 CFR Section 668.59 (b) - For the Federal Pell Grant Program, if an applicant?s FAFSA information changes as a result of verification, an institution must? (1) Recalculate the applicant?s Federal Pell Grant on the basis of the EFC on the corrected valid SAR or valid ISIR; and (2)(i) Disburse any additional funds under that award only if the institution receives a corrected valid SAR or valid ISIR for the applicant and only to the extent that additional funds are payable based on the recalculation; (ii) Comply with the procedures specified in ?668.61 for an interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced; or? (iii) Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced. 34 CFR Section 668.59 (c) - For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an applicant?s FAFSA information changes as a result of verification, the institution must? (1) Adjust the applicant?s financial aid package on the basis of the EFC on the corrected valid SAR or valid ISIR; and (2)(i) Comply with the procedures specified in ?668.61 for an interim disbursement if, as a result of verification, the financial aid package must be reduced; (ii) Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an FSEOG overpayment that is not the result of an interim disbursement if, as a result of verification, the financial aid package must be reduced; and (iii) Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan excess loan proceeds that are not the result of an interim disbursement if, as a result of verification, the financial aid package must be reduced. Condition Of 25 selections tested for verification procedures, two instances were noted in which the number of family household members enrolled in eligible postsecondary institutions per the ISIR did not agree to the amount included on the subsequently obtained verification form. In these instances, management did not update the information prior to awarding and disbursing Federal Aid to the students. Cause Management calculated aid eligibility based on the ISIR data. The students then submitted the verification forms after completion of ISIR with a different number of family household members enrolled in eligible postsecondary institutions, which was not caught timely by management in the standard verification procedures. Effect The calculation of the students? eligibility for Federal Aid was determined with partially incorrect data. One student received additional institutional aid in lieu of additional Federal aid. Questioned Costs None. Recommendation Management should enhance the monitoring control in place for review of verification procedures being completed timely. The enhanced control should include a second level of review to ensure that all students selected for verification procedures have been verified accurately and timely. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Villanova University Management's Views and Corrective Action Plan Management's Response Finding 2019-001: Verification The University agrees with this finding. As a result, the University will take the following action: Students selected for verification based on their FAFSA submission will have a second level of review of the Federal Student Aid by a member of the senior management team. This action will improve monitoring control and will help ensure that the correct data is used when determining eligibility for Federal Aid.
Finding 2019-002 Student Loan Repayments Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.038, 93.264 Title: Federal Perkins Loan Program, Nurse Faculty Loan Program Award Year: 6/2018 ? 5/2019 Criteria 34 CFR 674.2 (b) ? The Secretary defines other terms used in this part as follows: Initial grace period: That period which immediately follows a period of enrollment and immediately precedes the date of the first required repayment on a loan. This period is generally nine months for Federal Perkins loans. 34 CFR 674.38 (a)(5) ? In the case of an in school deferment, the institution may grant the deferment based on student enrollment information showing that a borrower is enrolled as a regular student on at least a half-time basis, if the institution notifies the borrower of the deferment and of the borrower?s option to cancel the deferment and continue paying on the loan. 34 CFR 674.43(b)(1) - An institution shall send a first overdue notice within 15 days after the due date for a payment if the institution has not received - (i) A payment; (ii) A request for deferment; or (iii) A request for postponement or for cancellation. Condition Of 77 selections tested for repayment procedures: ? Thirteen instances were noted in which the initial grace period exceeded 9 months, ranging from 15 months to 152 months, with an average of 33 months. ? Four instances were noted in which supporting documentation did not include documentation of student eligibility for loan deferment. ? Five instances were noted in which required interviews, contacts, billing procedures and collection procedures were not carried out by the entity in a timely manner. The first overdue notice was sent 48 days following the missed payment. Cause In May 2018, management changed their loan servicer. During the conversion, not all records completely transferred from the previous servicer to the new servicer. As such, management could not provide adequate documentation for the twenty-two instances noted. Effect Failure to retain complete documentation related to grace periods, deferments, and collection procedures could result in untimely loan repayments. Questioned Costs None. Recommendation Management should obtain and review all missing documentation and establish monitoring controls to ensure that all required notifications are sent, and all required documentation is maintained. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-002 Student Loan Repayments Grantor: Department of Education Program: Student Financial Assistance Cluster CFDA: 84.038, 93.264 Title: Federal Perkins Loan Program, Nurse Faculty Loan Program Award Year: 6/2018 ? 5/2019 Criteria 34 CFR 674.2 (b) ? The Secretary defines other terms used in this part as follows: Initial grace period: That period which immediately follows a period of enrollment and immediately precedes the date of the first required repayment on a loan. This period is generally nine months for Federal Perkins loans. 34 CFR 674.38 (a)(5) ? In the case of an in school deferment, the institution may grant the deferment based on student enrollment information showing that a borrower is enrolled as a regular student on at least a half-time basis, if the institution notifies the borrower of the deferment and of the borrower?s option to cancel the deferment and continue paying on the loan. 34 CFR 674.43(b)(1) - An institution shall send a first overdue notice within 15 days after the due date for a payment if the institution has not received - (i) A payment; (ii) A request for deferment; or (iii) A request for postponement or for cancellation. Condition Of 77 selections tested for repayment procedures: ? Thirteen instances were noted in which the initial grace period exceeded 9 months, ranging from 15 months to 152 months, with an average of 33 months. ? Four instances were noted in which supporting documentation did not include documentation of student eligibility for loan deferment. ? Five instances were noted in which required interviews, contacts, billing procedures and collection procedures were not carried out by the entity in a timely manner. The first overdue notice was sent 48 days following the missed payment. Cause In May 2018, management changed their loan servicer. During the conversion, not all records completely transferred from the previous servicer to the new servicer. As such, management could not provide adequate documentation for the twenty-two instances noted. Effect Failure to retain complete documentation related to grace periods, deferments, and collection procedures could result in untimely loan repayments. Questioned Costs None. Recommendation Management should obtain and review all missing documentation and establish monitoring controls to ensure that all required notifications are sent, and all required documentation is maintained. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Villanova University Management's Views and Corrective Action Plan Management's Response Finding 2019-002: Student loan Repayments The University agrees with this finding. This finding is a result of the difficulty the University had to produce supporting documentation for selected accounts due to the previously mentioned change in loan servicers. In May 2018, the University changed their loan servicer as a result of the previous loan servicer no longer providing the services needed by the University. The new loan servicer did not meet the needs or expectations of management or the University, and as a result, the University changed its loan servicer again in March 2019. This new loan servicer is meeting the needs of the University, and we do not expect to have these same issues going forward. Loan servicing for the University's students are compliant with federal regulations. The Bursar's Office will review each selected account to determine which accounts are current and which accounts need collection attention. Furthermore, the Bursar's Office will be working with our current loan servicer to determine what best practices can be implemented to be able to review documentation maintenance and compliance in relation to timing of notices.
FAC accepted this audit on February 26, 2019 — management decision was due August 26, 2019.
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2017-005
FAC accepted this audit on February 27, 2018 — management decision was due August 27, 2018.
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2016-002
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2016-003
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2016-005
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2016-007
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2016-008
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2016-010
FAC accepted this audit on February 27, 2017 — management decision was due August 27, 2017.
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