La Roche UniversityHigher Education

EIN: 251125048

UEI: MJGBD8AMDVT4

Audited by: BAKER TILLY US, LLP

Oversight agency: 84 [Department of Education]

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Data as of August 28, 2026

La Roche University10 audit years16 findings4 repeat
10
Audit Years
16
Total Findings
4
Repeat Findings
$18.7M
Federal Awards Expended (FY 2025)

FY 2025-06-30

LOW-RISK AUDITEE$18,688,041 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 18, 2026. 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 18, 2026 (20 days from today).

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2025-001
Special Tests & Provisions
OTHER MATTERS

The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for one student with a status change in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendations: The University should review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Views of Responsible Officials: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

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Full finding narrative

Federal Program - Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency - U.S. Department of Education Assistance Listing Number - 84.268 Federal Award Year - June 30, 2025 Criteria: Title IV regulations (34 CFR Section 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: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for one student with a status change in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendations: The University should review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Views of Responsible Officials: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new standard operating procedure regarding the reporting of students who have notified us of their withdrawal from the University at the end of spring term/early summer. Identified Error: La Roche University reports enrollment through the National Student Clearinghouse (NSC), which then reports to NSLDS. Because summer is not a mandatory reporting period, if a student is not enrolled they are not coded as withdrawn until they do not return in the fall; only on the first of fall enrollment report would they be coded as withdrawn. This does not meet the reporting timeline to NSLDS if we know a student is not planning to return. This only presents as an issue with the length of time between the end of spring and start of fall term; this is not an issue between the end of fall and start of spring term. New Procedure: If a student submits a Withdrawal form at the end of spring term through the first week of August, we must manually report them as withdrawn in NSC, as we know their intention to not return. Any forms submitted beginning in mid to late August will be picked up on the first of fall enrollment report as withdrawn and still fall within the reporting timeline. Name(s) of Contact Person(s) Responsible for Corrective Action • Katie Elverson, Registrar Anticipated Completion Date Implementation begins in May 2026 and will continue being implemented in all summers going forward.

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2025-002
Special Tests & Provisions
OTHER MATTERS

The federal aid disbursed resulting in a credit balance for one of the 25 students tested was not returned within 14 days of the date the credit balance occurred. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures did not allow for timely payment of the funds to the student due to holidays that occurred. Effect: The University was in possession of funds belonging to the student for four days longer than allowed. Recommendation: The University should increase emphasis on timely processing of refund transactions. Views of Responsible Officials: Management acknowledges and concurs with the finding and returned the funds 18 days after the credit balance was created. The University plans to complete a comprehensive review of procedures to increase emphasis on timely payments of credit balances.

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Federal Program - Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency - U.S. Department of Education Assistance Listing Number - 84.268 Federal Award Year - June 30, 2025 Criteria: 34 CFR 668.165 requires that when Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, the institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after the credit balance occurred. Condition: The federal aid disbursed resulting in a credit balance for one of the 25 students tested was not returned within 14 days of the date the credit balance occurred. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures did not allow for timely payment of the funds to the student due to holidays that occurred. Effect: The University was in possession of funds belonging to the student for four days longer than allowed. Recommendation: The University should increase emphasis on timely processing of refund transactions. Views of Responsible Officials: Management acknowledges and concurs with the finding and returned the funds 18 days after the credit balance was created. The University plans to complete a comprehensive review of procedures to increase emphasis on timely payments of credit balances.

Corrective Action Plan

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payment of the funds to the student due to holidays that occurred. The Office of Student Accounts has implemented enhanced controls to ensure that credit balances are reviewed and issued refunds in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action • Frank Corona, Controller • Dayna Tinkey, Director of Student Accounts Anticipated Completion Date All corrective actions were implemented as of February 12, 2026.

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2025-003
Special Tests & Provisions
OTHER MATTERS

The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly and the student received excess aid. The sample was not a statistically valid sample. Cause: The University's procedures for the processing of financial aid were in the process of being developed due to turnover in the financial aid department. Questioned Costs: There are no reportable questioned costs associated with this finding. Effect: The University awarded excess aid. Recommendation: The University should increase review and controls to ensure students are not awarded excess aid. Views of Responsible Officials: Management acknowledges and concurs with the finding. The University has a new team overseeing the financial aid process and plans to complete a comprehensive review of procedures and controls to ensure proper awarding in the future.

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Federal Program - Student Financial Assistance Cluster, Federal Pell Grant Program Federal Agency - U.S. Department of Education Assistance Listing Number - 84.063 Federal Award Year - June 30, 2025 Criteria: 34 CFR 690 requires Pell grants to be calculated in accordance with the defined parameters. Condition: The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly and the student received excess aid. The sample was not a statistically valid sample. Cause: The University's procedures for the processing of financial aid were in the process of being developed due to turnover in the financial aid department. Questioned Costs: There are no reportable questioned costs associated with this finding. Effect: The University awarded excess aid. Recommendation: The University should increase review and controls to ensure students are not awarded excess aid. Views of Responsible Officials: Management acknowledges and concurs with the finding. The University has a new team overseeing the financial aid process and plans to complete a comprehensive review of procedures and controls to ensure proper awarding in the future.

Corrective Action Plan

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant calculations in accordance with Title IV regulations and U.S. Department of Education Pell Grant payment and disbursement guidance. Immediate Correction of Identified Error The affected student’s Pell Grant award was recalculated using the correct Scheduled Pell amount and enrollment intensity. The overaward was resolved in accordance with federal overpayment and reconciliation requirements, and the Common Origination and Disbursement (COD) system was updated accordingly. Pell Calculation Verification Control A mandatory secondary review process has been implemented for all Pell-eligible students prior to disbursement to prevent future occurrences noted in this finding. This control collectively mitigates the risk of recurrence and strengthen institutional compliance with federal eligibility and disbursement requirements. Name(s) of Contact Person(s) Responsible for Corrective Action • Lawrence Britton, Executive Director of Financial Aid • Ron Elmore, Associate Director of Financial Aid Anticipated Completion Date All corrective actions were implemented as of February 9, 2026.

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FY 2024-06-30

LOW-RISK AUDITEE$16,552,339 federal awards expended

FAC accepted this audit on March 25, 2025 — management decision was due September 25, 2025.

2024-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

The federal aid refunds for one of the five students tested were not returned within 45 days of the date of the withdrawal. The sample was not a statistically valid sample. Cause: The University’s procedures for the return of Title IV funds were not followed. In addition, there was not a consistent independent review of the refund calculations. Effect: The University was in possession of funds belonging to the federal government longer than allowed. Questioned Costs: There were approximately $39,000 of known and likely questioned costs. Recommendation: The University should increase emphasis on timely processing of refund transactions. Views of Responsible Officials: Management acknowledges and concurs with the finding and has corrected the student records discovered in the audit. The University plans to complete a comprehensive review of past withdrawals to ensure timely returns were completed. Additionally, the University will be implementing additional controls and procedures to ensure returns are reviewed and processed timely.

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Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: The federal aid refunds for one of the five students tested were not returned within 45 days of the date of the withdrawal. The sample was not a statistically valid sample. Cause: The University’s procedures for the return of Title IV funds were not followed. In addition, there was not a consistent independent review of the refund calculations. Effect: The University was in possession of funds belonging to the federal government longer than allowed. Questioned Costs: There were approximately $39,000 of known and likely questioned costs. Recommendation: The University should increase emphasis on timely processing of refund transactions. Views of Responsible Officials: Management acknowledges and concurs with the finding and has corrected the student records discovered in the audit. The University plans to complete a comprehensive review of past withdrawals to ensure timely returns were completed. Additionally, the University will be implementing additional controls and procedures to ensure returns are reviewed and processed timely.

Corrective Action Plan

Enhance Student Withdrawal Notification System • La Roche University has an automatic notification system in place that notifies necessary parties of when a student withdrawals or takes a leave of absence (LOA). The notification of withdrawals and LOA is currently directed to the general financial aid email. We will add the Financial Aid Counselor to the notification system to receive the notifications directly in addition to the general financial aid email. Conduct a Comprehensive Review of Past R2T4 Transactions • Conduct a Comprehensive Review of Past R2T4 Transactions over the current academic year to ensure correctly processed R2T4 calculations and accuracy of returns. Assign a designated compliance officer and backup within the Financial Aid Office to oversee R2T4 calculations. • Office of Financial Aid will designate one person to complete all R2T4 calculations for process continuity. • Designate a financial aid staff backup to perform in absence of designated staff member Conduct mandatory training for all financial aid, student accounts, and registrar staff on Title IV compliance requirements. Revise internal Financial Aid Policies and Procedures

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FY 2023-06-30

LOW-RISK AUDITEE$16,666,121 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 15, 2024 — management decision was due August 15, 2024.

FY 2022-06-30

LOW-RISK AUDITEE$21,593,605 federal awards expended

FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.

2022-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001OTHER MATTERS

Finding 2022-001: Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-002 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

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Finding 2022-001: Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-002 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

Finding 2022-001 Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes of Graduated. The student in question graduated in December 2021. Per the assistant registrar, the degree verify files for both undergraduate and graduate students for December 2021 graduates were uploaded to the National Student Clearinghouse on 1/7/2022. It appears that the undergraduate file was processed by the graduate student file was not. We receive processing confirmations from the Clearinghouse, but when files are submitted in multiples, only one confirmation is received for all files, not separate confirmation. Corrective Action: The assistant registrar has been in communication with the National Student Clearinghouse regarding the missed file. The upload has been resolved. Going forward, the assistant registrar will submit each file separately to receive separate confirmations, and personally verify posting. Responsibility: Degree Verify reporting is uploaded by the Assistant Registrar. Contact: Katie Elverson, Registrar Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 2 students that changed enrollment status mid-semester. The students in question enrolled in fall 2021 classes full-time and was reported as full-time in the initial enrollment report They withdrew from all classes on 9/15/2023 and 10/21/2021, respectively. In the enrollment reports following their withdrawal, the students were reported as less-than half-time, rather than withdrawn. Students were reported as withdrawn following the end of the term. These reports with statuses are pulled by the student information system, so this seems to have been an issue with the SIS; they are spot checked, but all rows cannot be manually checked and verified before submission. Corrective Action: Upon notification of this issue, I began to investigate the original data report that was pulled out of CX (our SIS) to determine where the error was coming from Upon viewing the Fall 2021 data for the students, I saw that after their withdrawal they were reported as enrolled in zero credits, however they were also being classified in the report from CX as 'less than half time.' I immediately contacted Jenzabar (our SIS vendor) to inquire as to why the system would be calculating a zero-credit enrollment as 'less than half time.' They quickly responded and showed me how to adjust tables within CX that determine how student statuses are completed. Information in the tables was incomplete regarding students who withdraw midsemester. Bringing this to our attention enabled us to implement a corrective solution. Unfortunately, this solution will not be seen on enrollment reports until March 2023. Responsibility: Enrollment reporting is uploaded by the Registrar. Contact: Katie Elverson, Registrar

Prior Finding References

2021-001

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2022-002
Special Tests & Provisions
OTHER MATTERS

Finding 2022-002 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: 1 refund in a sample of 4 was returned at the incorrect amount and resulted in the University returning excess funds. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The calculation of the unearned portion of the grant or loan to be returned was completed correctly but the incorrect amount was returned. Effect: The University processed incorrect refunds. Recommendation: The University should modify its procedures for processing the returns to ensure the correct amount is returned. Management Response: Calculations to determine the unearned portion of the grant or loan to be returned will be completed with applicable dates and required aid adjustments. Evaluation of procedures will be on-going as a best practice.

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Finding 2022-002 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: 1 refund in a sample of 4 was returned at the incorrect amount and resulted in the University returning excess funds. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The calculation of the unearned portion of the grant or loan to be returned was completed correctly but the incorrect amount was returned. Effect: The University processed incorrect refunds. Recommendation: The University should modify its procedures for processing the returns to ensure the correct amount is returned. Management Response: Calculations to determine the unearned portion of the grant or loan to be returned will be completed with applicable dates and required aid adjustments. Evaluation of procedures will be on-going as a best practice.

Corrective Action Plan

Finding 2022-002 Issue: The University completed a Return to Title IV (R2T4) worksheet and returned more unearned aid than the school was responsible for per the calculation. The R2T4 calculation and return of funds was completed in a timely fashion but the amount of unearned Direct PLUS Loan funds was not properly scheduled by the counselor. Program closeout for the year has been completed and no adjustment can be made to reclaim funds at this time. While no financial liability has fallen upon the student or parent borrower the Financial Aid Office agrees with the finding of inaccuracy. Corrective Action: The University began implementation of an enhanced procedure for Return to Title IV calculations beginning with Fall 2022 semester and includes a detailed review of all calculations to ensure compliance & accuracy. Responsibility: Identification & evaluation of students will be completed by office staff and reviewed by the Director of Financial Aid. Contact: Robert Clemens, Director of Financial Aid

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2022-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Finding 2022-003: Significant Deficiency Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007; 84.033; 84.038; 84.063; 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 668.165) states that institutions must notify students or parents 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; 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. Condition/Context: 25 students in a sample of 25 were not given notifications that met the required criteria. Students were notified of awards throughout the academic year, but notifications did not meet the required criteria above. Additionally, the required information on the timing and procedures for canceling loans was made available to students on the University's website and financial aid office The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The script written in the University's software to send these notifications broke during September 2021 and was not fixed timely. Effect: The students did not receive the required notifications. Recommendation: The University should correct the software error and create a contingency plan to manually notify students to prevent awarding Title IV funds without proper notification. Management Response: The University will correct the script error and implement better procedures to ensure compliance with notification requirements. Evaluation will be on-going as a best practice.

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Finding 2022-003: Significant Deficiency Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007; 84.033; 84.038; 84.063; 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 668.165) states that institutions must notify students or parents 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; 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. Condition/Context: 25 students in a sample of 25 were not given notifications that met the required criteria. Students were notified of awards throughout the academic year, but notifications did not meet the required criteria above. Additionally, the required information on the timing and procedures for canceling loans was made available to students on the University's website and financial aid office The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The script written in the University's software to send these notifications broke during September 2021 and was not fixed timely. Effect: The students did not receive the required notifications. Recommendation: The University should correct the software error and create a contingency plan to manually notify students to prevent awarding Title IV funds without proper notification. Management Response: The University will correct the script error and implement better procedures to ensure compliance with notification requirements. Evaluation will be on-going as a best practice.

Corrective Action Plan

Finding 2022-003 Issue: The University utilizes an automated notification system to send an email message to students when federal loans are disbursed. The message includes (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; 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. However, as a result of a technical issue the automated notification system stopped working in September, 2021. Corrective Action: As of March 10, 2023, the University corrected the technical system scripts that failed approximately 19 months ago; as a result, students are once again receiving automated email notifications when federal aid is posted to their accounts. Responsibility: Director, Student Accounts Contact: Dayna Tinkey, Director, Student Accounts

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FY 2021-06-30

LOW-RISK AUDITEE$18,520,732 federal awards expended

FAC accepted this audit on September 26, 2022 — management decision was due March 26, 2023.

2021-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2020-002OTHER MATTERS

Finding 2021-001 - Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2021 Repeat of Prior Year Finding 2020-002 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for five students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

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Finding 2021-001 - Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2021 Repeat of Prior Year Finding 2020-002 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for five students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

Finding 2021-001 Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes of Graduated. The students in question graduated in August 2020 and were included in the degree verify file for August 2020 graduates uploaded to the National Student Clearinghouse on 10/19/2020. This file was uploaded late due to work-from-home miscommunication over who was uploading the file. Corrective Action: This was two years ago. The Registrar?s Office staff has entirely changed positions and/or has new team members. Effective July 2021, the Assistant Registrar is now responsible for uploading the Degree Verify reports and he does so the day after he runs the degree conferral; he has built this step into his process and has it as a documented step on his degree conferral check-list. Degrees are conferred 1-3 weeks after the posted graduation date. Responsibility: Degree Verify reporting is uploaded by the Assistant Registrar. Contact: Katie Elverson, Registrar Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for a student?s change in status. The student in question enrolled in spring 2021 classes after the first day of the semester (January 25th), but still within the add/drop period. The next enrollment report was due to the Clearinghouse on March 1. This student?s enrollment status was reported to the Clearinghouse on March 1, but it did not report to NSLDS until March 26th. The previous Registrar uploaded the initial enrollment report to the Clearinghouse on the first day of classes, missing a lot of the first week course adding and dropping that was occurring. Corrective Action: This was over 1.5 years ago. The Registrar?s Office staff has entirely changed positions and/or has new team members. Effective July 2021, the Registrar now uploads the initial enrollment report to the Clearinghouse after the last day of add/drop has passed when enrollment is much more stable, to ensure that all last-minute enrollments are included and the initial report uploaded is as accurate as possible. Responsibility: Enrollment reporting is uploaded by the Registrar. Contact: Katie Elverson, Registrar

Prior Finding References

2020-002

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2021-002
Special Tests & Provisions
OTHER MATTERS

Finding 2021-002 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2021 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: One refund in a sample of three was not returned within 45 days. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The calculation of the unearned portion of the grant or loan to be returned was completed late due to unusual circumstances of the student?s withdrawal. Effect: The University failed to make one refund in the required timeframe. Recommendation: The University should modify its procedures disbursing refunds in a timely manner. Management Response: The University will adhere to making timely determinations of unofficial withdraws for students that do not successfully complete coursework during the semester. Calculations to determine the unearned portion of the grant or loan to be returned will be completed with applicable dates and required aid adjustments. Evaluation of procedures will be on-going as a best practice.

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Finding 2021-002 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2021 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: One refund in a sample of three was not returned within 45 days. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The calculation of the unearned portion of the grant or loan to be returned was completed late due to unusual circumstances of the student?s withdrawal. Effect: The University failed to make one refund in the required timeframe. Recommendation: The University should modify its procedures disbursing refunds in a timely manner. Management Response: The University will adhere to making timely determinations of unofficial withdraws for students that do not successfully complete coursework during the semester. Calculations to determine the unearned portion of the grant or loan to be returned will be completed with applicable dates and required aid adjustments. Evaluation of procedures will be on-going as a best practice.

Corrective Action Plan

Finding 2021-002 Issue: The University processed a Return to Title IV (R2T4) calculation outside the 45-day requirement. The R2T4 for a student was completed late due to unique & unusual circumstances. The student did not pass any coursework during the Fall 2020 semester and the process of determining whether the student completed the payment period was hindered by remote work access due to COVID-19, the lack of withdrawal notification by the student, and the inability to contact the student due to enlisting in the military upon leaving the institution. The unofficial withdraw determination was made beyond the required timeframe making the calculation and subsequent aid adjustments out of compliance. The Financial Aid Office agrees with the finding. Corrective Action: The University will adhere to making timely determinations of unofficial withdraws for students that do not successfully complete coursework during the semester. Withdrawal date determinations will be made no later than 30 days after the end of the earliest of the (1) payment period or period of enrollment, (2) academic year, or (3) educational program, as appropriate. R2T4 calculations will be completed with applicable dates and required aid adjustments will be made accordingly. Implementation will begin with Fall 2022 semester Return to Title IV calculations and continue as a best practice. Responsibility: Identification & evaluation of students will be completed by office staff and reviewed by the Director of Financial Aid. Contact: Robert Clemens, Director of Financial Aid

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2021-003
Eligibility
QUESTIONED COSTSOTHER MATTERS

Finding 2021-003 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2021 Criteria: Title IV regulations (34 CFR 685.203) states that students are limited in the amount of Direct Loans awarded dependent upon year of enrollment and other factors Condition/Context: One student in a sample of 25 was awarded Unsubsidized Direct Loans in excess of the allowable limits. The sample was not a statistically valid sample. Questioned Costs: The student was awarded an excess of $4,000 in Unsubsidized Direct Loans Cause: The initial Parent PLUS loan decision for the student was denied and additional unsubsidized loan funds were awarded to the student. A subsequent PLUS loan request was made by the other parent, they were approved, and a Parent PLUS loan was awarded. The additional unsubsidized loan was not cancelled, and the oversight was identified during the audit. Effect: The student received a Direct Unsubsidized loan that the student was not eligible to receive. Recommendation: The University should revise its procedures for awarding Student Financial Aid, including Federal Direct Loans, to ensure that aid is awarded correctly and that controls are in place to prevent overawards of Title IV funds. Management Response: The University will implement a compliance check to ensure students with Parent PLUS loans do not inadvertently receive additional unsubsidized loan funds. Parent PLUS loan reports will be run periodically through the semester/academic year to identify recipients and will be cross-referenced against student loan records. Students that are awarded more than the baseyear amounts will be evaluated by Financial Aid Office staff to ensure we are compliant with Federal Student Aid rules related to additional loan awards. Evaluation will be on-going as a best practice.

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Finding 2021-003 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2021 Criteria: Title IV regulations (34 CFR 685.203) states that students are limited in the amount of Direct Loans awarded dependent upon year of enrollment and other factors Condition/Context: One student in a sample of 25 was awarded Unsubsidized Direct Loans in excess of the allowable limits. The sample was not a statistically valid sample. Questioned Costs: The student was awarded an excess of $4,000 in Unsubsidized Direct Loans Cause: The initial Parent PLUS loan decision for the student was denied and additional unsubsidized loan funds were awarded to the student. A subsequent PLUS loan request was made by the other parent, they were approved, and a Parent PLUS loan was awarded. The additional unsubsidized loan was not cancelled, and the oversight was identified during the audit. Effect: The student received a Direct Unsubsidized loan that the student was not eligible to receive. Recommendation: The University should revise its procedures for awarding Student Financial Aid, including Federal Direct Loans, to ensure that aid is awarded correctly and that controls are in place to prevent overawards of Title IV funds. Management Response: The University will implement a compliance check to ensure students with Parent PLUS loans do not inadvertently receive additional unsubsidized loan funds. Parent PLUS loan reports will be run periodically through the semester/academic year to identify recipients and will be cross-referenced against student loan records. Students that are awarded more than the baseyear amounts will be evaluated by Financial Aid Office staff to ensure we are compliant with Federal Student Aid rules related to additional loan awards. Evaluation will be on-going as a best practice.

Corrective Action Plan

Finding 2021-003 Issue: The University awarded additional unsubsidized Direct Loan funds to a dependent student that received a Parent PLUS loan. The initial Parent PLUS loan decision was denied and additional unsubsidized loan funds were awarded to a student. A subsequent PLUS loan request was made by the other parent, which was approved, and a Parent PLUS loan was awarded. The additional unsubsidized loan was not cancelled and the oversight was identified during the audit. The Financial Aid Office agreed with the finding and returned the additional unsubsidized loan funds accordingly. Corrective Action: The University will implement a compliance check to ensure students with Parent PLUS loans do not inadvertently receive additional unsubsidized loan funds. Parent PLUS loan reports will be run periodically through the semester/academic year to identify recipients and cross-referenced against student loan records. Records that are awarded more than the base-year amounts will be evaluated by Financial Aid Office staff to ensure we are compliant with Federal Student Aid rules related to additional loan awards. Implementation will begin effective August 2022 and evaluation will be on-going as a best practice. Responsibility: Reporting & evaluation will be completed by office staff and reviewed by the Director of Financial Aid. Contact: Robert Clemens, Director of Financial Aid

About Eligibility →

FY 2020-06-30

LOW-RISK AUDITEE$14,271,574 federal awards expended

FAC accepted this audit on June 21, 2021 — management decision was due December 21, 2021.

2020-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2019-002OTHER MATTERS

Finding 2020-002 - Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education CFDA: 84.268 Federal Award Year: June 30, 2020 Repeat of Prior Year Finding 2019-002 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for one student with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

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Finding 2020-002 - Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education CFDA: 84.268 Federal Award Year: June 30, 2020 Repeat of Prior Year Finding 2019-002 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for one student with status changes in our sample of 25 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

This memo is in response to the recent audit findings 2020-002 and includes a corrective action plan for the issue identified. Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student out of a sample size of 25 with status changes. The student in question graduated in December, 2019 and was included in the degree verify file for December 2019 graduates uploaded to the National Student Clearinghouse on 01/24/2020.The NSLDS generated an error in the G to DV process, so the student was not recognized as having graduated (no status change to G). As a result of the student?s status not being changed to G, and not appearing on the Spring 2020 enrollment file, his status was changed to W. G to DV errors are required to be resolved within 10 days by the University. The error was resolved late on 2/10/2020, however we missed by one day, the 60-day window for reporting student status changes to the NSLDS. The change from W to G had to be made manually. Corrective Action: The University worked with the National Student Clearinghouse Audit Resource Team to create a schedule for uploading degree verify files that ensures that our files are received in time to resolve any G to DV errors and still to meet the 60-day NSLDS window. This schedule coincides with the Clearinghouse schedule for pushing data to NSLDS, which is typically the first of the month, and then again between the 11th and 16th of the month. Now that we have this schedule we can ensure our files are uploaded accordingly and that 10 days to resolve G to DV errors are is built into the schedule. Please let me know if I can provide any clarification on the above. I can be reached by phone at 412-536-1079 or by email at joan.cutone@laroche.edu

Prior Finding References

2019-002

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FY 2019-06-30

LOW-RISK AUDITEE$13,601,863 federal awards expended

FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.

2019-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2018-001OTHER MATTERS

Finding 2019-002 ? Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education CFDA: 84.268 Federal Award Year: June 30, 2019 Repeat of Prior Year Finding 2018-001 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 6 students with status changes in our sample of 40 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

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Finding 2019-002 ? Significant Deficiency Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education CFDA: 84.268 Federal Award Year: June 30, 2019 Repeat of Prior Year Finding 2018-001 Criteria: Title IV regulations (34 CFR Section 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 University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 6 students with status changes in our sample of 40 students. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. 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. Recommendation: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

This memo is in response to the recent audit Finding 2019-002 related to status change reporting to the National Student Loan Data System Notification Issue: As stated in the audit finding, National Student Loan Data System (?NSLDS?) notification was not completed within the required thirty-day timeframe for reporting status changes; in this case, graduation. Corrective Action Plan 1: Several of the students identified during audit testing had unique circumstances that resulted in the noted audit finding. Specifically, they were retroactively graduated to a date that was more than 30 days in the past, thus outside the 30-day required reporting deadline. NSLDS however, was notified immediately on the date that retroactive graduation was granted. There is potential for this to happen in the future, and La Roche University will continue to report the status change immediately upon retroactive degree conferral. Corrective Action Plan 2: Routinely, and within 30 days of each graduation semester, a ?degree file (DV)? is uploaded to the NSC where a process called the ?G from DV? changes the student?s status to G (graduated). Please see detail below from NSC: ?If the records within the degree file meet the criteria to have a G status generated in our enrollment database, NSC will automatically create a graduates only enrollment file, containing students on the `G Applied? tab to be loaded into NSC?s enrollment database, which would then be available to be sent to NSLDS. ?If the records within the degree file do not meet the criteria (see G from DV Resource Document links? for reasons as to why a record may not met the criteria) to have a G status generated in our enrollment database, they will appear on the `G Not Applied? tab and NSC encourages schools to report the G status for these students via NSC?s enrollment reporting options. La Roche University had established a review procedure of all NSCs ?G Not Applied? errors, but has since hired an Assistant Registrar, Katie Elverson, who now has primary responsibility for graduation processing and uploading degree files. She will ensure proper resolution of the ?G Not Applied? errors within the required time frame, and has been doing that since her hire in July of 2019. This finding did not create any financial liability for the University. Please let me know if I can provide any clarification on the above. I can be reached by phone at 412- 536-1079 or by email at joan.cutone@laroche.edu Sincerely, Joan M. Cutone

Prior Finding References

2018-001

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2019-003
Eligibility
QUESTIONED COSTSOTHER MATTERS

For 1 student tested out of 40, the incorrect year of enrollment was used when calculating the student's award package. The sample was not considered statistically valid. Context: The total Direct loans disbursed to the 40 students tested during fiscal year 2019 was $474,762. A total of 901 students received Direct Loans during fiscal year 2019. Questioned Costs: The total Direct loans disbursed to the one student tested during fiscal year 2019 exceed the maximum limit by a total $2,000. Cause: The University's system incorrectly calculated credits for the affected student when determining year of enrollment. Effect: This error resulted in the student receiving an award package for which they were not eligible, based on an inaccurate year of enrollment. Recommendation: We recommend the University put enhanced policies and controls in place for awarding Student Financial Aid, including Federal Direct Loans, to ensure that aid is awarded correctly and based on the correct year of enrollment. Management Response: Management concurs with the finding. Management will implement enhanced monitoring of loan origination data and enhance exception reporting over award packages.

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Finding 2019-003 Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education CFDA: 84.268 Federal Award Year: June 30, 2019 Criteria: Title IV regulations (34 CFR Section 685.203) states limits to the amount of a Direct Subsidized or Direct Unsubsidized loan based on the student's year of enrollment. Condition: For 1 student tested out of 40, the incorrect year of enrollment was used when calculating the student's award package. The sample was not considered statistically valid. Context: The total Direct loans disbursed to the 40 students tested during fiscal year 2019 was $474,762. A total of 901 students received Direct Loans during fiscal year 2019. Questioned Costs: The total Direct loans disbursed to the one student tested during fiscal year 2019 exceed the maximum limit by a total $2,000. Cause: The University's system incorrectly calculated credits for the affected student when determining year of enrollment. Effect: This error resulted in the student receiving an award package for which they were not eligible, based on an inaccurate year of enrollment. Recommendation: We recommend the University put enhanced policies and controls in place for awarding Student Financial Aid, including Federal Direct Loans, to ensure that aid is awarded correctly and based on the correct year of enrollment. Management Response: Management concurs with the finding. Management will implement enhanced monitoring of loan origination data and enhance exception reporting over award packages.

Corrective Action Plan

2019-003: Direct Loans ? Incorrect year of enrollment utilized for 1 student As stated in the audit finding, grade-level status was reported incorrectly for a student. Initial packaging offered grade-level 2 awards in subsidized & unsubsidized Direct Loans. Upon loan origination, the CX system added both transfer and anticipated 2018-19 coursework which resulted in an erroneous gradelevel 3 update of the record that was not caught by staff. Greater attention to these details at loan origination will be asked of staff to prevent future occurrences of this issue. Effective January 29, 2020 exception reporting for the award year will be implemented by the Assistant Director, Robert Clemens, and monitored monthly during periods of peak loan originations. This plan will remain in place for the remainder of the 2019-20 award year and the upcoming 2020-21 award year.

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2019-004
Special Tests & Provisions
OTHER MATTERS

Finding 2019-004 Federal Program: Student Financial Assistance Cluster, Federal Pell Grant Program Federal Agency: U.S. Department of Education CFDA: 84.063 Federal Award Year: June 30, 2019 Criteria: An institution is required to verify applications selected by the Central Processing System of students who will receive or have received subsidized student financial assistance. Furthermore, an institution is required to complete verification for a selected student before the institution makes changes to the student's cost of attendance or to the values of the data items required to calculate the estimated family contribution (EFC) (34 CFR Section 668.53). The institution is required to verify applicable information using the specified year income tax return or other acceptable IRS form (34 CFR Section 668.57). Condition/Context: For 1 student tested out of 40, the income reported on the Free Application for Federal Student Aid (FAFSA) did not tie to the supporting income tax return. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: A typographical error occurred during the calculation of the student's tax information. As a result, an incorrect adjusted gross income figure was utilized on the student's FAFSA. Effect: The affected student could potentially have been awarded Federal funds that they were not eligible for, or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. The error did not have an impact on the amount awarded. Recommendation: We recommend that the University implement additional review procedures and train employees to ensure that all aspects of the verification process are completed accurately. Management Response: Management concurs with the finding. Management will add additional review procedures to ensure verifications are completed using the correct information from supporting documentation.

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Finding 2019-004 Federal Program: Student Financial Assistance Cluster, Federal Pell Grant Program Federal Agency: U.S. Department of Education CFDA: 84.063 Federal Award Year: June 30, 2019 Criteria: An institution is required to verify applications selected by the Central Processing System of students who will receive or have received subsidized student financial assistance. Furthermore, an institution is required to complete verification for a selected student before the institution makes changes to the student's cost of attendance or to the values of the data items required to calculate the estimated family contribution (EFC) (34 CFR Section 668.53). The institution is required to verify applicable information using the specified year income tax return or other acceptable IRS form (34 CFR Section 668.57). Condition/Context: For 1 student tested out of 40, the income reported on the Free Application for Federal Student Aid (FAFSA) did not tie to the supporting income tax return. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: A typographical error occurred during the calculation of the student's tax information. As a result, an incorrect adjusted gross income figure was utilized on the student's FAFSA. Effect: The affected student could potentially have been awarded Federal funds that they were not eligible for, or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. The error did not have an impact on the amount awarded. Recommendation: We recommend that the University implement additional review procedures and train employees to ensure that all aspects of the verification process are completed accurately. Management Response: Management concurs with the finding. Management will add additional review procedures to ensure verifications are completed using the correct information from supporting documentation.

Corrective Action Plan

2019-004: Verification ? Wrong AGI used As stated in the audit finding, AGI was reported incorrectly for a student selected for the verification process. This instance was a typographical error that occurred during the calculation of separate tax information for the student?s parents. This error had no adverse impact on aid eligibility for the student or create any financial liability for the University. Effective January 29, 2020 all ISIR corrections made during the verification process will be reviewed by the Assistant Director, Robert Clemens, to ensure the accuracy of corrected ISIR data. This plan will remain in place for the remainder of the 2019-20 award year and the upcoming 2020-21 award year.

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FY 2018-06-30

LOW-RISK AUDITEE$14,177,692 federal awards expended

FAC accepted this audit on March 25, 2019 — management decision was due September 25, 2019.

2018-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-06-30

LOW-RISK AUDITEE$13,999,512 federal awards expended

FAC accepted this audit on March 13, 2018 — management decision was due September 13, 2018.

2017-001
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-06-30

LOW-RISK AUDITEE$13,638,868 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 8, 2017 — management decision was due September 8, 2017.

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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