Marywood University

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 numbers: 84.063, 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). Condition: Certain students? enrollment effective dates were not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted 3 students out of a sample of 40 students were reported to the NSLDS with the incorrect enrollment effective date on the campus and program level records in the NSLDS and 1 student out of a sample of 40 was reported to the NSLDS with the incorrect enrollment effective date on the program level records only. Cause: The University was not using the last day of attendance as the students? effective date of the status change when reporting to the NSLDS. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001. Auditors? Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

2022-001 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus level and program level records submitted to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was addressed in February 2023, the Registrar's office met with the Office of Financial Aid to determine what date on a student's withdraw application is the correct to Clearinghouse reporting. Name(s) of the contact person(s) responsible for corrective action: Bill Manley, Registrar Planned completion date for corrective action plan: Complete

2021-001

2022-002 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 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: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2021 and Spring 2022 term. Questioned costs: $355. Context: During our testing, we noted 5 out of 7 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2021 or Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes, 2021-003. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

2022-002 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was corrected once identified in the FY21 single audit, however, due to timing of that audit, it was a repeat finding for 2022. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Completed May 2022

2021-003

2022-003 ? Direct Loan Reconciliations 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, an institution must reconcile the institutional records with the Direct Loan funds received from ED as well as to the Direct Loan disbursement records submitted to and accepted by ED (34 CFR 685.300(b)(5)). Condition: During our testing it was noted that a direct loan reconciliation was not completed on a timely basis. Questioned costs: None. Context: During our testing, we noted 1 out of 3 monthly reconciliations selected was not completed on a timely basis. Cause: The University experienced turnover and the reconciliation was not completed on a timely basis. Effect: The University did not comply with its internal policy and federal requirements to ensure funds are properly reconciled monthly. Repeat Finding: No. Auditors? Recommendation: The University should ensure employees receive proper training, support, and time to follow the University?s policies and federal requirements related to monthly reconciliations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

2022-003 Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reconciliations have occurred in the Financial aid office, however, the sample selection occurred during the month when a transition in director occurred. The reconciliation was completed a month late. Reconciliations have now been improved by including other offices in the process and have been placed on a regular schedule. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Complete

2022-004 ? Exit Counseling 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: The Code of Federal Regulations, 34 CFR 685.304 requires entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who cease at least half-time study at the school. Condition: Exit counseling was not completed. Questioned costs: None. Context: During our testing, we noted 1 student out of a sample of 40 tested where the University failed to notify the student to complete exit counseling. Cause: The University?s process and controls did not ensure that the student was notified, and that proper support was maintained to document the process took place. Effect: A student did not receive the proper loan counseling which may contribute to a higher default rate. Repeat Finding: No. Auditors? Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student files. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This error also occurred during the transition period of the previous Financial Aid Director and winter graduates were forgotten to be notified. The Financial Aid Office has updated its procedures and have been in discussions with the IT Department to automate the process. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Complete.

2021-001 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.063, 84.268 Award period: 7/1/2020 ? 6/30/2021 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). Condition: Certain students? enrollment effective dates were not reported accurately to the NSLDS. Questioned costs: None. Context: During our testing, we noted 2 out of a sample of 40 students were reported to the NSLDS with the incorrect enrollment effective date on the campus level records in the NSLDS. Cause: The University was using the last day the student was enrolled in the prior semester rather than the date the change in status took place.

2021-001 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in the campus level records submitted to the National Student Loan Data System (NSLDS). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar office reports to the Clearinghouse every 30 days. The impacted students have been identified and remedied. When processing leaves of absence and withdrawals, the Registrar's Office will process the leave or withdrawal only after receiving a fully executed form including the signatures of the student and the representative of the Office of Academic Success. It is no longer our practice to remove the student from class on one date and process the leave on another date in the future. Name(s) of the contact person(s) responsible for corrective action: William Manley, (570) 961-4503 Planned completion date for corrective action plan: June 30, 2022

2021-002 ? Gramm-Leach-Bliley Act (GLBA) Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2020 ? 6/30/2021 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: In accordance with Title IV regulations, the University is required to designate an individual to coordinate the information security program, perform a risk assessment that addresses (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures, and document safeguards for identified risks (16 CFR 314.1(b)). Condition: While the University had documented an individual responsible for coordinating the information security program, the University had not completed a risk assessment outlining identified risks and related safeguards in place. Questioned costs: None. Context: During our audit procedures, it was noted that the University did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4(b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University did not perform a risk assessment until after June 30, 2021. Effect: Failure to comply with the GLBA standards puts the University at risk of compromising student personal information. Repeat Finding: No. Auditors? Recommendation: We recommend the University perform a risk assessment to identify risks, quantify the impact of potential threats, and provide an economic balance between the impact of risk and the cost of the safeguard. Views of responsible officials: See the corrective action plan.

2021-002 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University perform a risk assessment to identify risks, quantify the impact of potential threats, and provide an economic balance between the impact of risk and the cost of the safeguard. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In early 2022, the University adopted an official and documented security program which describes/defines security incidents and events, an incident response team (including roles and responsibilities), and incident response stages (including activities and deliverables leading to mitigation and/or resolution). The University has also implemented a plan and conducted an annual risk assessment in fiscal 2022 that addresses employee training and management, information systems (including network and software design, and information processing, storage, transmission and disposal), and ongoing and continual detecting, preventing and responding to attacks, intrusions, or other system failures, and has documented safeguards for each aforementioned risk identified. The University has identified and documented external and internal risks to security, confidentiality, and integrity of covered data that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. The University has also assessed and documented the sufficiency of safeguards in place to control the identified risks. The responsible parties work with all relevant departments and vendors to carry out comprehensive risk assessments. Name(s) of the contact person(s) responsible for corrective action: James M. Dutcher, (570) 961-4504 Planned completion date for corrective action plan: Completed prior to June 30, 2022

2021-003 ?Return of Title IV (R2T4) - Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Federal assistance listing numbers: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/2020 ? 6/30/2021 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the University?s process did not ensure scheduled breaks were properly factored in the R2T4 calculations for the Fall 2020 term. Questioned costs: $296. Context: During our testing, we noted 7 out of 8 instances where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Fall 2020 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: No. Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Views of responsible officials: See the corrective action plan.

2021-003 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The R2T4 calculation has been revised and scheduled breaks built into it for 22-23. Financial Aid has included in our policies and procedures to check this screen moving forward, to ensure the breaks are included every year. Due to the timing of the FY `21 Single Audit, this issue may occur again in FY `22 but has been mitigated in FY `23. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, (570) 961-4704 OR Robert Piurowski, (570) 961-4728 Planned completion date for corrective action plan: Complete as of July 1, 2022

Finding 2020-001 ? Significant Deficiency - Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year ? June 30, 2020 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 2 of 25 students tested were not reported accurately or timely to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Cause: Due to a data issue at National Student Clearinghouse (NSC), both of the student records identified above, failed to process as graduated and were not transmitted by NSC to NSLDS until September 2020. Because the 2 students were not included the fall 2020 enrollment files sent to NSC, NSC defaulted their status to withdrawn and reported them to NSLDS as such in September. The students were ultimately reported to NSLDS in December 2020. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: None. Recommendation: We recommend the University review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by regulations described above. View of Responsible Officials and Planned Corrective Action: The University agrees with the finding. The NSC has developed a report of "G" enrollment status not applied for schools to be able to track the issue and has provided documentation to the University on how to identify where the data anomaly resides which caused the graduated status to fail to apply to the student and how to resolve it. The University Registrar's Office will monitor this report after sending the first certification file of each semester to ensure that this error does not reoccur going forward. Once reporting to the NSC is completed, additional follow-up will be performed to ensure statuses are ultimately reported to the NSLDS within the required timeframe.

Finding 2020-001: Enrollment Reporting Condition The change in student status for 2 of 25 students tested were not reported accurately or timely to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The University agrees with the finding. The NSC has developed a report of ?G? enrollment status not applied for schools to be able to track the issue and have provided documentation to the University on how to identify where in the data anomaly resides which caused the graduated status to fail to apply to the student and how to resolve it. The University Registrar?s Office will monitor this report after sending the first certification file of each semester to ensure that this error does not reoccur going forward. Once reporting to the NSC is completed, additional follow-up will be performed to ensure statuses are ultimately reported to the NSLDS within the required timeframe. Name(s) of Contact Person(s) Responsible for Corrective Action: Ann Boland-Chase, VP Enrollment Management Anticipated Completion Date: Marywood University has already begun the performing corrective actions above.