EIN: 231413680
UEI: KPVBKSDMPJ95
Audited by: CLIFTONLARSONALLEN LLP
Cognizant agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 12, 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 September 12, 2025 (354 days ago).
What is a management decision? →FAC accepted this audit on January 12, 2024 — management decision was due July 12, 2024.
FAC accepted this audit on January 29, 2023 — management decision was due July 29, 2023.
Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following: ? Three students, out of a sample of 40 students tested, were not reported to the campus-level record in the NSLDS in a timely manner. ? One student of the three noted above, out of a sample of 40 students tested, was not reported to the campus-level record in the NSLDS every 60 days. At a minimum, schools are required to certify enrollment every 60 days. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University's system and the NSLDS. There are also times the University updates certain information on students after reports are sent to the third-party servicer and these changes are not being captured on the reporting to the third-party servicer to the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-002. Auditors? Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: See the corrective action plan.
Show full finding ▾Hide full finding ▴2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following: ? Three students, out of a sample of 40 students tested, were not reported to the campus-level record in the NSLDS in a timely manner. ? One student of the three noted above, out of a sample of 40 students tested, was not reported to the campus-level record in the NSLDS every 60 days. At a minimum, schools are required to certify enrollment every 60 days. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University's system and the NSLDS. There are also times the University updates certain information on students after reports are sent to the third-party servicer and these changes are not being captured on the reporting to the third-party servicer to the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-002. Auditors? Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: See the corrective action plan.
Auditor?s Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University reviews its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Corrective Action Plan: Two of the incidents identified by the audit were students who graduated in the middle of summer term, which was not identified in NSC as a required term. This classification has been corrected at NSC. Current Process ? Director of Financial Aid and two Assistant Registrar?s meet monthly to audit 10-20 records per meeting. Record of students who graduated off cycle, withdrew, went on leave of absence, or were dismissed were specifically reviewed. Effective January 2023, the Office of the Registrar will add students to the monthly sample who returned after a period of non-enrollment, students with more than one active program, and all graduates (on time and off cycle). The audits will take place in both NSC and NSLDS, ensuring that students marked as graduated and re-enrolled are not only reported correctly and on time in NSC, but that the data is the same in NSLDS. Secondly, the Office of the Registrar worked with Salus Technology Services to modify a report to assist with identifying discrepancies between campus level and program level enrollment. The program level date is now included on the internal audit report. Lastly, an Assistant Registrar will take on a more active role in auditing enrollment data prior to submission to NSC providing another set of eyes on the data. A training reference document was provided to the Assistant Registrar on 12/12/22. Name(s) of the contact person(s) responsible for corrective action: Shannon Boss, Registrar Jaime Schulang, Director of Student Financial Aid
2021-002
FAC accepted this audit on June 13, 2022 — management decision was due December 13, 2022.
In our sample of 40 students tested, 1 student was reported to the NSLDS with an incorrect status and program begin date at the program level. Questioned Costs: None Context: 1 student out of a sample of 40 status changes selected for testing was reported with an inaccurate status and program start date at the program level only. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third party incorrectly communicates information to the NSLDS which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the student?s grace period should begin. Repeat Finding: Yes, prior year finding number 2020-002. Auditors? Recommendation: We recommend the University review procedures around inputting dates in the Jenzebar system to ensure they are input correctly. Additionally, we recommend the University develop a process that helps them better oversee the submissions completed by the third-party servicer. Views of Responsible Officials: See the corrective action plan.
Show full finding ▾Hide full finding ▴2021?001 ? National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.033, 84.038, 84.268, 93.342 Award Period: 7/1/20-6/30/21 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: In our sample of 40 students tested, 1 student was reported to the NSLDS with an incorrect status and program begin date at the program level. Questioned Costs: None Context: 1 student out of a sample of 40 status changes selected for testing was reported with an inaccurate status and program start date at the program level only. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third party incorrectly communicates information to the NSLDS which results in discrepancies between the University?s system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the student?s grace period should begin. Repeat Finding: Yes, prior year finding number 2020-002. Auditors? Recommendation: We recommend the University review procedures around inputting dates in the Jenzebar system to ensure they are input correctly. Additionally, we recommend the University develop a process that helps them better oversee the submissions completed by the third-party servicer. Views of Responsible Officials: See the corrective action plan.
2021-001 Student Financial Assistance Cluster ? Federal Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University review procedures around inputting dates in the Jenzabar system to ensure they are input correctly. Additionally, we recommend the University develop a process that helps them better oversee the submissions completed by the third-party servicer. Action taken in response to finding: The finding in this audit was for a student who completed prior to an automated process being put into place. The University recently went through a major student information system upgrade (Jenzabar) and has implemented an automated process within the system to override incorrect start dates so that the accurate information is reported to the NSC and NSLDS. In addition to a line-by-line audit of the enrollment file prior to NSC submission, the Assistant Registrar and Director of Student Financial Aid have adopted a standing meeting each month to review records. If reporting problems persist, the Registrar Office will work with the Financial Aid Office to determine if we can report directly to NSLDS and bypass the NSC. Name(s) of the contact person(s) responsible for corrective action: Registrar, and Director of Student Financial Aid Planned completion date for corrective action plan: Immediately
2020-002
In our sample of 40 students tested, 1 student was not timely reported to NSLDS. Questioned Costs: None Context: 1 student out of a sample of 40 status changes selected for testing were reported outside the required timeframe. Cause: Student?s change in status was not picked up by the third-party servicer causing inaccurate reporting to NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the student?s grace period should begin. Repeat Finding: Yes, prior year finding number 2020-002. Auditors? Recommendation: We recommend the University review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Additionally, we recommend the University develop a process that helps them better oversee the submissions completed by the third-party servicer. Views of Responsible Officials: See the corrective action plan.
Show full finding ▾Hide full finding ▴2021?002 ? National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.033, 84.038, 84.268, 93.342 Award Period: 7/1/20-6/30/21 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that Roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits (34 CFR 682.610). Condition: In our sample of 40 students tested, 1 student was not timely reported to NSLDS. Questioned Costs: None Context: 1 student out of a sample of 40 status changes selected for testing were reported outside the required timeframe. Cause: Student?s change in status was not picked up by the third-party servicer causing inaccurate reporting to NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the student?s grace period should begin. Repeat Finding: Yes, prior year finding number 2020-002. Auditors? Recommendation: We recommend the University review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Additionally, we recommend the University develop a process that helps them better oversee the submissions completed by the third-party servicer. Views of Responsible Officials: See the corrective action plan.
2021-002 Student Financial Assistance Cluster ? Federal Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Additionally, we recommend the University develop a process that helps them better oversee the submissions completed by the third-party servicer. Action taken in response to finding: At the beginning of December 2020, the Financial Aid Office provided the Registrar?s Office with a detailed report of records from NSLDS. The Registrar?s Office used this report to identify graduates with incorrect dates on their record, as well as current enrollees with incorrect dates on their record. Updates were made via request to the Financial Aid Office and NSC for graduates, and updates were made to current enrollees via the enrollment update feature in NSC. This finding is a file that had an incorrect start date listed, which has since been updated in NSLDS by the Financial Aid Office. Name(s) of the contact person(s) responsible for corrective action: Registrar, and Director of Student Financial Aid Planned completion date for corrective action plan: An automated process has been added to our student information system to override incorrect start dates so that the accurate information is reported to the NSC and NSLDS. In addition to a line-by-line audit of the enrollment file prior to NSC submission, the Assistant Registrars and Director of Student Financial Aid have adopted a standing meeting each month to review records.
2020-002
During our testing we noted that the quarterly reporting for the student portion of the funding for the periods 10/1/2020-12/31/2020 and 4/1/2021-6/30/2021, as well as the quarterly reporting for the institutional portion of the funding for the periods 7/1/2020-9/30/2020 and 1/1/2021-3/31/2021 were not posted to the University?s website within the required 10-day timeframe. We also noted that the quarterly report for the student portion of the funding for the period 4/1/2021-6/30/2021 did not include the following required documentation: (1) the signed certification and (2) the required information to make students aware of where they can access information on awards. In addition, this report included total funding and expenditures for both the student and institutional portions, where it should have only included the funds available to students. Additionally, the University is not maintaining all reports on the website, as required, for both institutional and student awards. Questioned Costs: None Context: Reporting requirements are not being met. Cause: Reports not accurately or timely reported for both the student and institutional portions of the funding. Effect: Not in compliance with reporting requirements. Repeat Finding: No. Auditors? Recommendation: We recommend the University review the reporting requirements to ensure they are in compliance. We also recommend the University to upload past reports to their website. Views of Responsible Officials: See the corrective action plan.
Show full finding ▾Hide full finding ▴2021?003 ? Education Stabilization Fund Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund Federal Assistance Listing Number: 84.425E, 84.425F Award Period: 7/1/20-6/30/21 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Under section 18004(e) of the CARES Act, Public Law 116-36, 134 Statute 281 directs institutions receiving funds to submit a report to the secretary describing the use of funds distributed under the Higher Education Emergency Relief Fund (HEERF). A separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. Institutions of higher education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which was due July 10, 2021. In addition, certain required disclosures were to be made available in the reports. Condition: During our testing we noted that the quarterly reporting for the student portion of the funding for the periods 10/1/2020-12/31/2020 and 4/1/2021-6/30/2021, as well as the quarterly reporting for the institutional portion of the funding for the periods 7/1/2020-9/30/2020 and 1/1/2021-3/31/2021 were not posted to the University?s website within the required 10-day timeframe. We also noted that the quarterly report for the student portion of the funding for the period 4/1/2021-6/30/2021 did not include the following required documentation: (1) the signed certification and (2) the required information to make students aware of where they can access information on awards. In addition, this report included total funding and expenditures for both the student and institutional portions, where it should have only included the funds available to students. Additionally, the University is not maintaining all reports on the website, as required, for both institutional and student awards. Questioned Costs: None Context: Reporting requirements are not being met. Cause: Reports not accurately or timely reported for both the student and institutional portions of the funding. Effect: Not in compliance with reporting requirements. Repeat Finding: No. Auditors? Recommendation: We recommend the University review the reporting requirements to ensure they are in compliance. We also recommend the University to upload past reports to their website. Views of Responsible Officials: See the corrective action plan.
2021-003 Education Stabilization Fund ? Federal Assistance Listing No. 84.425 Recommendation: We recommend the University review the reporting requirements to ensure they are in compliance. We also recommend the University upload past reports to their website. Action taken in response to finding: The specific regulations pertaining to periodic reporting were not entirely clear. Upon further review of the reporting requirements, the university will update their website to include a copy of each quarterly report and upload subsequent reports within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Director of Sponsored Programs, and Director of Student Financial Aid Planned completion date for corrective action plan: 6/30/22
FAC accepted this audit on June 10, 2021 — management decision was due December 10, 2021.
Not all of the required language (per 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds) is included in the executed contract between the University and ECSI. Questioned costs: None Context: The University?s contract with ECSI did not include the language required by 34 CFR 668.25(c). Cause: The University did not have procedures in place to ensure that their contract with ECSI included the language required by 34 CFR 668.25(c). Effect: ECSI?s contract with the University did not include the language required by 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds. Any finding ECSI receives becomes a finding of the institution they service. Repeat finding: No. Recommendation: When contracting with an institution for performing or providing any relevant Title IV function, the servicer and/or any of its contractors, essentially ?steps into the shoes? of the institution with respect to compliance with the requirements for institutional administration of the Title IV student assistance program activity. The institution must ensure that its contract with any third-party servicer contains the required elements outlined in the regulations at 34 CFR 668.25(c). This can be done through contract review and inquiry of the third-party servicer.
Show full finding ▾Hide full finding ▴2020?001 ? Contracts with Third-Party Servicer Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.038 Award Period: 7/1/19-6/30/20 Type of Finding: Other Matters Criteria or specific requirement: The University utilizes a third-party service provider, Educational Computer Systems, Inc. (ECSI), to perform certain functions related to the servicing of the University?s Federal Perkins Loan Program. Regulations require that an institution and a third-party service provider shall agree to comply with all requirements of 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds. 34 CFR 668.25(c) states that in a contract with an institution, a third-party servicer shall agree to: ? Comply with all statutory or regulatory provisions, and special arrangements, agreements, limitations, suspensions, and terminations entered into under Title IV programs; ? Refer to the Office of Inspector General of the U.S. Department of Education for investigation any information indicating there is reasonable cause to believe that: o The institution might have engaged in fraud or other criminal misconduct in connection with the institution?s administration of any Title IV program, or o An applicant for Title IV program assistance might have engaged in fraud or other criminal misconduct in connection with his or her application; ? Be jointly and severally liable with the institution for any violation by the servicer of any statutory or regulatory provisions, and special arrangements, agreements, or limitations entered into under Title IV programs Condition: Not all of the required language (per 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds) is included in the executed contract between the University and ECSI. Questioned costs: None Context: The University?s contract with ECSI did not include the language required by 34 CFR 668.25(c). Cause: The University did not have procedures in place to ensure that their contract with ECSI included the language required by 34 CFR 668.25(c). Effect: ECSI?s contract with the University did not include the language required by 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds. Any finding ECSI receives becomes a finding of the institution they service. Repeat finding: No. Recommendation: When contracting with an institution for performing or providing any relevant Title IV function, the servicer and/or any of its contractors, essentially ?steps into the shoes? of the institution with respect to compliance with the requirements for institutional administration of the Title IV student assistance program activity. The institution must ensure that its contract with any third-party servicer contains the required elements outlined in the regulations at 34 CFR 668.25(c). This can be done through contract review and inquiry of the third-party servicer.
Student Financial Assistance Cluster - CFDA No. 84.038 Recommendation: When contracting with an institution for performing or providing any relevant Title IV function, the servicer and/or any of its contractors, essentially "steps into the shoes" of the institution with respect to compliance with the requirements for institutional administration of the Title IV student assistance program activity. The institution must ensure that its contract with any third-party servicer contains the required elements outlined in the regulations at 34 CFR 668.25(c). This can be done through contract review and inquiry of the third-party servicer . Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University was in process of renewing and updating this contract at the time of the audit. We will ensure reference to 34 CFR 668.25 (c) is included in the new contract. Name(s) of the contact person(s) responsible for corrective action: Donald Kates Planned completion date for corrective action plan: May 1st, 2021
During our testing, we noted the following: ? 1 student out of a sample of 25 students tested was reported to the NSLDS with the incorrect enrollment status at the campus level. ? 1 student out of a sample of 25 students tested that was reported to the NSLDS with an incorrect enrollment status at the program level. ? 12 students out of a sample of 25 students tested were reported to the NSLDS with the incorrect effective date at both the campus level and program level. ? 5 students out of sample of 25 students tested that were reported to the NSLDS with the incorrect effective date at the program level only. ? 17 students out of a sample of 25 students tested that were reported to the NSLDS with the incorrect program begin date at the program level. ? 1 student out of a sample of 25 students tested that was reported to the NSLDS outside the required timeframe. Questioned costs: None Context: The University did not adhere to its review policies in overseeing submissions to the NSLDS completed by the third-party servicer. In one instance, a student enrollment status change was not reported timely due to an oversight. Cause: The University has the ultimate responsibility to ensure that reporting is correct. The University?s ERP system generated enrollment reports with incorrect data which resulted in discrepancies in information being reported to NSLDS. In one instance, a student status change was not reported timely to NSLDS. Effect: The enrollment effective date reported to the NSLDS is used to determine when the student?s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. Additionally, in one instance, the University did not comply with ED regulations by not timely reporting a student?s enrollment status change. Repeat Finding: The student status change not reported timely to NSLDS is a repeat finding (2019-001). Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies in overseeing submissions to the NSLDS. Additionally, we recommend the University review its policies and procedures on reporting enrollment status changes to the NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Views of responsible officials: See the corrective action plan
Show full finding ▾Hide full finding ▴2020?002 ? National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.033, 84.038, 84.268, 93.342 Award Period: 7/1/19-6/30/20 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: During our testing, we noted the following: ? 1 student out of a sample of 25 students tested was reported to the NSLDS with the incorrect enrollment status at the campus level. ? 1 student out of a sample of 25 students tested that was reported to the NSLDS with an incorrect enrollment status at the program level. ? 12 students out of a sample of 25 students tested were reported to the NSLDS with the incorrect effective date at both the campus level and program level. ? 5 students out of sample of 25 students tested that were reported to the NSLDS with the incorrect effective date at the program level only. ? 17 students out of a sample of 25 students tested that were reported to the NSLDS with the incorrect program begin date at the program level. ? 1 student out of a sample of 25 students tested that was reported to the NSLDS outside the required timeframe. Questioned costs: None Context: The University did not adhere to its review policies in overseeing submissions to the NSLDS completed by the third-party servicer. In one instance, a student enrollment status change was not reported timely due to an oversight. Cause: The University has the ultimate responsibility to ensure that reporting is correct. The University?s ERP system generated enrollment reports with incorrect data which resulted in discrepancies in information being reported to NSLDS. In one instance, a student status change was not reported timely to NSLDS. Effect: The enrollment effective date reported to the NSLDS is used to determine when the student?s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. Additionally, in one instance, the University did not comply with ED regulations by not timely reporting a student?s enrollment status change. Repeat Finding: The student status change not reported timely to NSLDS is a repeat finding (2019-001). Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies in overseeing submissions to the NSLDS. Additionally, we recommend the University review its policies and procedures on reporting enrollment status changes to the NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Views of responsible officials: See the corrective action plan
Student Financial Assistance Cluster- CFDA No. 84.033, 84.038, 84.268, 93.342 Recommendation : We recommend the University reevaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment status changes to the NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding: At the beginning of December 2020, Salus identified all graduates with incorrect dates on their record, as well as current enrollees with incorrect dates on their record. Updates were made to the Clearinghouse for graduates, and updates were made to current enrollees via the enrollment update feature in the Clearinghouse . Since we learned of this issue, every enrollment file that has been submitted (about 3 to 5 enrollment reports per month) has been reviewed prior to submission to the Clearinghouse . Our Registrar Department prepares an enrollment report to obtain the list of students along with their start date and enrollment status. This report is then compared line-by-line. Any discrepancies are corrected in the history file in the ERP system (so that the next time the report is run the correct information pulls in) and are also overridden in the TXT file that is ultimately uploaded to the Clearinghouse . Withdrawals and graduates are reported via the enrollment update feature through the Clearinghouse. In addition to the line-by-line audit of the enrollment file prior to the Clearinghouse submission, the Assistant Registrars and Director of Student Financial Services have adopted a standing meeting each month to review records. Name(s) of the contact person(s) responsible for corrective action : Shannon Boss - Registrar Jaime Schulang - Director of Student Financial Aid Planned completion date for corrective action plan: We are currently working with ERP provider to correct the problem.
2019-001
In our sample of 8 students tested, 1 student?s timesheet was not approved by a supervisor. Questioned costs: None Context: In the one instance noted, the supervisor did not follow the University?s established process. Cause: The campus was closed due to COVID-19 and the supervisor was unable to sign the timesheet. It was noted that management developed a new approval method for remote working, however, the supervisor did not follow the process in this particular instance. Effect: The timesheet was not reviewed and approved prior to issuing a check to the student. Repeat Finding: No. Auditors? Recommendation: We recommend that all supervisors approving timesheets be trained in the procedures for working remotely. Views of responsible officials: See the corrective action plan.
Show full finding ▾Hide full finding ▴2020?003 ? Federal Work Study Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.033 Award Period: 7/1/19-6/30/20 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 675.19(b)(2)(i)) states that an institution must follow the record retention and examination provisions when administering the federal work study program. The institution must establish and maintain program and fiscal records that include a certification by the student?s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. Condition: In our sample of 8 students tested, 1 student?s timesheet was not approved by a supervisor. Questioned costs: None Context: In the one instance noted, the supervisor did not follow the University?s established process. Cause: The campus was closed due to COVID-19 and the supervisor was unable to sign the timesheet. It was noted that management developed a new approval method for remote working, however, the supervisor did not follow the process in this particular instance. Effect: The timesheet was not reviewed and approved prior to issuing a check to the student. Repeat Finding: No. Auditors? Recommendation: We recommend that all supervisors approving timesheets be trained in the procedures for working remotely. Views of responsible officials: See the corrective action plan.
Student Financial Assistance Cluster - CFDA No. 84.033 Recommendation: We recommend that all supervisors approving timesheets be trained in the procedures for working remotely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On March 13, 2020 the Commonwealth of Pennsylvania directed that all Pennsylvania colleges and universities would be closed for at least two weeks. Payroll was processed two business days after the closure without an electronic approval process in place. Shortly thereafter, the University developed an electronic approval process whereby the payroll coordinator emailed a report containing student names, dates, and hours worked for electronic approval. Name(s) of the contact person(s) responsible for corrective action: Maureen Owens Planned completion date for corrective action plan: Completed
FAC accepted this audit on November 11, 2019 — management decision was due May 11, 2020.
In our sample of 25 students tested, 3 were not timely reported to NSLDS. Questioned costs: None Context: 3 students out of a sample of 25 status changes selected for testing were reported outside the required timeframe. Cause: 3 students out of a sample of 25 selected for testing withdrew after the first enrollment file was submitted. The students were not captured on the next scheduled submission. Effect: Student enrollment statuses were not timely reported to NSLDS. Repeat Finding: No. Auditors? Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Views of responsible officials: See the corrective action plan.
Show full finding ▾Hide full finding ▴2019?001 ? National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.033, 84.038, 84.268, 93.342 Award Period: 7/1/18-6/30/19 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, the school may provide the date on that Roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits (34 CFR 682.610). Condition: In our sample of 25 students tested, 3 were not timely reported to NSLDS. Questioned costs: None Context: 3 students out of a sample of 25 status changes selected for testing were reported outside the required timeframe. Cause: 3 students out of a sample of 25 selected for testing withdrew after the first enrollment file was submitted. The students were not captured on the next scheduled submission. Effect: Student enrollment statuses were not timely reported to NSLDS. Repeat Finding: No. Auditors? Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Views of responsible officials: See the corrective action plan.
U.S. Department of Education The Corporation of Salus University and Its Foundation respectfully submits the following corrective action plan for the year ended June 30, 2019. Audit period: July 01, 2018 to June 30, 2019 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education 2019-001 Student Financial Assistance Cluster ? CFDA No. 84.033, 84.038, 84.268, 93.342 Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All roster changes of withdrawn students are now individually updated with the NSC when the roster change takes effect. We no longer wait for the next scheduled roster submission to occur even if it is within the appropriate time frame for reporting. Additionally, we have two individuals within the Office of the Registrar monitoring the reporting schedule so that reports and submissions are processed in the event that one of the individuals is out of the office. Review by the Office of Financial Aid will be added to confirm that the change has been updated in the NSLDS system. Name(s) of the contact person(s) responsible for corrective action: Registrar?s Office ? Director of Financial Aid Planned completion date for corrective action plan: October 31, 2019
FAC accepted this audit on December 20, 2018 — management decision was due June 20, 2019.
FAC accepted this audit on November 13, 2017 — management decision was due May 13, 2018.
FAC accepted this audit on March 14, 2017 — management decision was due September 14, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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