UNION INSTITUTE & UNIVERSITY

Federal Program ? Federal Direct Student Loan Program, Federal Assistance Listing No. 84.268, 2021, Department of Education Criteria or Specific Requirement ? Special Tests and Provisions ? Management is responsible for reporting changes in student status to the National Student Loan DataSystem for Students (NSLDS). Changes in enrollment must be reported within 30 days. However, if a roster file is expected within 60 days, management may report the Status changes via that roster. The University is also required to correct any errors noted in the roster file within ten days.Context - From a sample of 15 student status changes tested (population of 94 student status changes), the change in status for five students was not reported accurately and/or timely to NSLDS. Our sampling method was not, and was not intended to be, statistically valid. Condition ? Changes in status for five students were not accurately and/or timely reported to NSLDS. Questioned Costs ? There were no questioned costs as a result of this finding. Effect ? Timely and accurate reporting of status changes is important because it is used to determine if the student is still considered enrolled, must be moved into repayment, or is eligible for an in-school deferment. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. Cause ? The primary cause for the reporting issues related to employee turnover in the position responsible for reporting student status changes and a lack of documented procedures to instruct new employees in continued timely reporting. Identification as a Repeat Finding ? No. Recommendation ? We recommend management formally document all reporting procedures to allow for continued compliance and procedural continuity where there is turnover in employee positions. Views of Responsible Officials and Planned Corrective Actions ? The University is aware of the issue related to the reporting of program start dates and entry dates between the University?s records and NSLDS. The program date generates in the University?s system on the degree tab. If the effective date is requested and not entered correctly, it will generate a program start date that is inaccurate. The University has reached out for assistance from the systems vendor, Jenzabar, in June 2021 prior to the audit. The University will continue to follow-up with Jenzabar on a weekly basis to request training. The University has implemented a process when a student decides to change majors to ensure the proper program start dates are being used. Additionally, the University has implemented an exit reason of ?changed majors? and are in the process of testing this change in order to help keep the program entry date for a specific program accurate.

Federal Program ? COVID-19 - Higher Education Emergency Relief Fund (HEERF) - Student, Federal Assistance Listing No. 84.425E, 2021 Criteria or Specific Requirement ? Reporting ? Institutions that received a HEERF I Student Aid Portion award were to publicly post certain award data on its website no later than 30 days after the award, and update that information every 45 days thereafter. On August 31, 2020, the requirement was decreased to every calendar quarter, with the first calendar quarter report due by October 30, 2020. On May 13, 2021, an additional notice for HEERF awards under CRRSAA and ARP, was issued requiring institutions publicly post additional award data on its website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date the institution was first obligated funds under HEERF I, II or III to the institution for emergency financial aid grants to student, whichever comes later. Condition ? Reports for the student aid portion were not submitted within five of the required due dates. Questioned Costs ? There were no questioned costs as a result of this finding. Context ? Five out of seven reports on the student aid portion were not reported timely on the institution?s website. Effect ? Timely and accurate reporting of emergency financial aid grants to students is important because it is used to publicly communicate information timely to the Department of Education, the general public and students of the institution. Cause ? The primary cause for the reporting issues related to a lack of documented procedures and designated individuals responsible for meeting these reporting requirements. Identification as a Repeat Finding ? No. Recommendation ? We recommend management designate individuals responsible for reporting these requirements timely and creating a formal schedule to allow for continued compliance of these reporting guidelines. Views of Responsible Officials and Planned Corrective Actions - The University has been diligent about complying with federal regulations in the selection of eligible student and the disbursement of HEERF funds to meet students? immediate needs arising from the impact of the coronavirus. The University prioritized high need students by focusing on $0 expected family contribution (EFC) and low EFC. The United States Department of Education?s initial reporting requirements were initially not very clear on how to report, and the timing of when to report changed throughout the fiscal year. The University is now clear on the current reporting requirements and will adhere to those deadlines. A new position has been created which will oversee the HEERF reporting process, including the timely posting of the reports on the public website. The new position is Special Assistant to the Vice President of Finance and Chief Financial Officer (VPF/CFO). The Special Assistant?s job duties include performing post-award accounting of more complex grants, interpreting regulations and guidelines of program funding for standard grants, and preparing reports for the applicable grant agencies. While the Special Assistant will report to the VPF/CFO, the Associate Vice President for Institutional Effectiveness will collaborate with the Special Assistant and ensure that the new process works as intended.

Federal Program - Federal Direct Student Loan Program, CFDA No. 84.268, 2019, Department of Education Criteria or Specific Requirement - Special Tests and Provisions - Management is responsible for reporting changes in student status to the National Student Loan Data System for Students (NSLDS). Changes in enrollment must be reported within 30 days. However, if a roster file is expected within 60 days, management may report the status changes via that roster. The University is also required to correct any errors noted in the roster file within ten days. Condition - Changes in status for four students were not accurately and/or timely reported to NSLDS. Questioned Costs - There were no questioned costs as a result of this finding. Context - From a sample of 25 student status changes tested (population of 247 student status changes), the change in status for four students were not reported accurately and/or timely to NSLDS. Our sampling method was not, and was not intended to be, statistically valid. Effect - Timely and accurate reporting of status changes is important because it is used to determine if the student is still considered enrolled, must be moved into repayment, or is eligible for an in-school deferment. For students moving into repayment, the out-ofschool status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. Cause - The primary cause for the reporting issues related to employee turnover in the position responsible for reporting student status changes and a lack of documented procedures to instruct new employees in continued timely reporting. Identification as a Repeat Finding - No. Recommendation - We recommend management formally document all reporting procedures to allow for continued compliance and procedural continuity when there is turnover in employee positions. Views of Responsible Officials and Planned Corrective Actions - In order to comply with the requirements for reporting changes in status of individual students, the University reports all student status changes to the National Student Loan Data System (NSLDS) through the National Student Clearinghouse (NSC), which is the nation?s leading provider of educational reporting and verification services to colleges and universities. Two of the four instances of non-timely status change reporting were actually reported to NSC timely as documented by NSC reports. For some reason, which is still unexplained, NSC did not submit all of the May 2019 and June 2019 changes to NSLDS. While the Financial Aid Office spot checks status change reporting to NSLDS throughout the year, these non-submissions were not found. The Financial Aid office will now receive notice from the Registrar?s office every time they do a new NSC submission. The Registrar?s office will provide several students? information within that submission. Financial Aid will then check to make sure that each submission does show up in NSLDS correctly. The other two students listed in the finding had enrolled in a term and then dropped their courses within a few days of enrolling. This would happen before the first submission to NSC for that term. We found that the NSC reporting produced by Union was not picking up students to report these status changes in this type of situation. This issue surfaced in mid-year (1819). At that time, the Registrar?s office developed new reports that select this set of circumstances so that the students in this situation would be identified and reported manually. These new reports are run at the time of each new submission to the clearinghouse and, with the utilization of these new reports and manual submission of the status change, this issue has been resolved. The Registrar?s office now has full documentation of all procedures required to process NSC status change reporting and this process is incorporated in the position requirements within the Registrar?s office.

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