CINCINNATI CHRISTIAN UNIVERSITY

Oversight of Student Financial Aid Department Federal Program Student Financial Aid Cluster Criteria: According to 2 CFR 200.303(a) the non-federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: A small number of individuals have the primary responsibility for performing most of the student financial aid duties. As a result, there is a lack of segregation of duties, specifically, the Associate Director of Financial Aid determines student eligibility for federal student financial aid, calculates Title IV refunds, and performs other procedures related to federal student financial aid that are not reviewed by another individual at the University which does not provide proper oversight of the student financial aid department. Enrollment Services and the Business Office did review Title IV activity resulting in refunds, applied knowledge to differentiate traditional refunds compared to Parent PLUS, uploaded refund files to a third party (TMS/Nelnet), and separately recorded, reviewed, and approved journal entries apart from the Associate Director of Financial Aid. Cause: Due to the limited number of personnel, adequate segregation of duties have not been maintained. Adequate procedures have not been established to review the activity related to student financial aid performed by the Associate Director of Financial Aid. Effect: Financial aid could be improperly awarded and errors could exist and not be detected. Questioned costs: Not determinable. No specific items noted. Context: Controls were not effectively designed to maintain proper segregation of duties. This finding was reported as finding 2019-003 in the prior year audit reporting package. Recommendation: In order to ensure that financial aid is awarded properly, the University should develop procedures that provide oversight and review of federal student financial aid activities. This would include the determination of eligibility, correspondence with students and the calculation of Title IV refunds. View of Responsible Officials: The University accepts this finding.

Enrollment Reporting - Student Financial Aid Cluster - CFDA#s 84.007, 84.033, 84.063, 84.268 - Grant Period - Seven months ended January 31, 2020 Criteria: According to 34 CFR 685.309 (b), schools must update enrollment data for students and report to the Secretary in a manner of prescribed format within the required timeframe of sixty days after a student has graduated, ceased attendance or enrolled less than half-time. Condition/Context: During our testing of the enrollment reporting to the National Student Loan Data System (NSLDS), we noted that forty-nine of the sixty-three students in our sample of withdraws and graduates were not reported with the required sixty days. We consider this Single Audit Finding to be an instance of noncompliance relating to the Reporting Compliance Requirement. Effect: The University did not report forty-nine students who ceased attendance or enrollment less than half time to the NSLDS within the sixty-day requirement. Cause: The University?s internal controls did not identify the fact that these students who did not official withdraw or graduated but were no longer attended the university after the school ceased operations, these students were not reported to NSLDS within the required sixty-day requirement. Recommendation: We recommend the University work with the department responsible for submission of withdraws and graduated students to the NSLDS to assume compliance within their reporting guidelines. View of Responsible Officials: The University accepts this finding. This is a repeat finding from 2019-004.

Oversight of Student Financial Aid Department Federal Program Student Financial Aid Cluster Criteria: According to 2 CFR 200.303(a) the non-federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: A small number of individuals have the primary responsibility for performing most of the student financial aid duties. As a result, there is a lack of segregation of duties, specifically, the Associate Director of Financial Aid determines student eligibility for federal student financial aid, calculates Title IV refunds, and performs other procedures related to federal student financial aid that are not reviewed by another individual at the University which does not provide proper oversight of the student financial aid department. Enrollment Services and the Business Office did review Title IV activity resulting in refunds, applied knowledge to differentiate traditional refunds compared to Parent PLUS, uploaded refund files to a third party (TMS/Nelnet), and separately recorded, reviewed, and approved journal entries apart from the Associate Director of Financial Aid. Cause: Due to the limited number of personnel, adequate segregation of duties have not been maintained. Adequate procedures have not been established to review the activity related to student financial aid performed by the Associate Director of Financial Aid. Effect: Financial aid could be improperly awarded and errors could exist and not be detected. Questioned costs: Not determinable. No specific items noted. Context: Controls were not effectively designed to maintain proper segregation of duties. This finding was reported as finding 2018-003 in the prior year audit reporting package. Recommendation: In order to ensure that financial aid is awarded properly, the University should develop procedures that provide oversight and review of federal student financial aid activities. This would include the determination of eligibility, correspondence with students and the calculation of Title IV refunds. View of Responsible Officials: The University accepts this finding and will make all reasonable efforts to implement the recommendation.

Enrollment Reporting - Student Financial Aid Cluster - CFDA#s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2019 Criteria: According to 34 CFR 685.309 (b), schools must update enrollment data for students and report to the Secretary in a manner of prescribed format within the required timeframe of sixty days after a student has graduated, ceased attendance or enrolled less than half-time. Condition/Context: During our testing of the enrollment reporting to the National Student Loan Data System (NSLDS), we noted that three of the twenty-six students in our sample of withdraws and graduates were not reported with the required sixty days. We consider this Single Audit Finding to be an instance of noncompliance relating to the Reporting Compliance Requirement. Effect: The University did not report three students who ceased attendance or enrollment less than half time to the NSLDS within the sixty-day requirement. Cause: The University?s internal controls did not identify the fact that these students were not reported to NSLDS within the required sixty-day requirement. Recommendation: We recommend the University work with the department responsible for submission of withdraws and graduated students to the NSLDS to assume compliance within their reporting guidelines. View of Responsible Officials: The University accepts this finding and will make all reasonable efforts to implement the recommendation.

Exit Counseling - Student Financial Aid Cluster - CFDA#s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2019 Criteria: According to 34 CFR section 668.42, 34 CFR section 682.604(g), 34 CFR section 685.304(b), IFAP Student Financial Aid Handbook, Volume 6 stipulate that the University must ensure that exit counseling is conducted with each borrower either in person, by audiovisual presentation, or by interactive electronic means. If a student borrower withdraws from school without the University's prior knowledge or fails to complete an exit counseling session as required, the University must ensure that exit counseling is provided through either interactive electronic means or by mailing written counseling materials to the student borrower at the student borrower's last known address within thirty days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required. During our testing of Student Financial Aid we noted one instance in a sample of fifty-five students in which evidence of exit counseling and notification of exit counseling could not be provided by the University. Condition: During our testing of the exit counseling for direct loans, we noted that one of the twenty-six students in our sample of withdraws and graduates in which evidence of exit counseling and notification of exit counseling within thirty days was not complete. Cause: The one student graduated during the Fall of 2018 and did not notify the school of the graduating status. The student did not attend the class for the spring of 2019 and was not notified to exit until April 2019 past the thirty-day notice from his graduation date. Effect: Not providing the necessary information or performing exit counseling timely may result in penalties and or sanctions from the Department of Education in addition to higher default rates. Recommendation: We recommend that the University implement procedures to ensure that borrowers who cease enrollment be notified to the need to complete exit counseling and evidence of exit counseling should be done within thirty days. View of Responsible Officials: The University accepts this finding and will make all reasonable efforts to implement the recommendation.

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