Lewis University

Information on the federal program – Department of Education – Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268 Criteria or specific requirement – Under the Pell grant and loan programs, schools must complete and return within 30 days the Enrollment Reporting roster file. Once received, the University must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a Pell grant or loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loans - 34 CFR 685.309(2))(i); Pell - 34 CFR 690.83(b)(2)). Condition – Notification of the student status change (graduated) did not reach the NSLDS within the required time frame. Questioned costs – None – nonmonetary finding. Context – NSLDS was not provided timely notification for three May and December graduates. Effect – NSLDS did not contain current information with respect to the status of these students. Cause – Due to an administrative oversight, the status of these students were not updated in the Enrollment Reporting Roster File sent to the NSLDS. Identification as a repeat finding, if applicable – N/A Recommendation – We recommend the University monitor and evaluate the schedule reporting dates to the NSLDS and confirm or modify existing policies, procedures, or processes for timely identification to ensure that status changes can be communicated to the NSLDS within the regulatory timeframes. Views of responsible officials and planned corrective actions – All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

2020-001 - Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268. Program Year ? July 1, 2019 ? June 30, 2020 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? Under the Pell grant and loan programs, universities must complete and return within 30 days the Enrollment Reporting roster file. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the University must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309). Condition ? Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required timeframe. Questioned Costs ? None. Context ? Out of a sample of 45 students from a population of 1,000 students who had changes in status during the year, NSLDS was not provided timely notification for 9 of the student status changes reviewed. Our sample was not, and was not intended to be, statistically valid. Effect ? NSLDS did not contain current information with respect to the student status of some students. Cause ? Information between the Clearinghouse and NSLDS was not updated timely. This could have been a result of the University?s data files not including the most recent information upon submission to the Clearinghouse. Identification as a Repeat Finding ? Yes, see 2019-001 Recommendation ? We recommend the University monitor and evaluate the scheduled reporting dates to the Clearinghouse. Also, confirm or modify existing formal policies, procedures or processes for timely identification or reporting lines that need to be informed to ensure that status changes can be communicated to NSLDS timely. Finally, we recommend the University implement a secondary review process to ensure those students with status changes are being properly reflected within NSLDS after the submission is received.

The exceptions surround the Fall 2019 graduate file submission. In the case of Fall 2019 graduate only file, there were several factors that led to the reporting issues. The Fall 2019 report was filed on January 24, 2020 along with the graduates only report (two files uploaded). Unfortunately, the file was mislabeled by NSC and received as a DegreeVerify file. This was unexpected since there had been several communications with NSC regarding the technology and process to upload a ?graduates only? file. We began to have many technical issues with NCS which are documented with our Registrar?s Office and the Lewis Office of Technology regarding the file upload through many external and internal emails. We have since corrected the technical issues, some of which were likely caused by the NSC enhancement implementation which caused known problems with student records. Please see attached NSC notification letter. Additionally, we have successfully submitted subsequent enrollment, degree and graduates only files well within the allotted time frame and deadline. All future file uploads will go through a secondary review process including an official file documentation in the Registrar?s Shared drive for review by the Registrar and Assistant Registrar each month. The NSC file uploads status will also be a standing agenda item and will be reported at all future department meetings. All graduate only files will be uploaded within thirty days of status change.

2019-001

2020-002 - Federal Program ? Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, CFDA 84.063; TEACH Grant, CFDA 84.379; Federal Work-Study Program, CFDA 84.033; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; and Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2019 ? June 30, 2020 Criteria or Specific Requirement ? Special Tests and Provisions ? Return of Title IV Funds ? 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 aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)). Condition ? The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University returned the incorrect amount of funds to the Department of Education because of the error in the calculation. Questioned Costs ? $225, Federal Direct Loans, CFDA 84.268 Context ? Of a sample of eight return of funds tested from a population of 51 performed during the examination period, two return of funds calculations were not performed correctly. This resulted in an incorrect amount of funds being returned to the Department of Education for two of those eight students. Our sample was not, and was not intended to be, statistically valid. Cause ? The number of days in the break for the Fall semester was calculated incorrectly when determining the enrollment period. Effect ? The University returned the incorrect amount of funds to the Department of Education. Identification as a Repeat Finding ? Yes, see 2019-003 Recommendation ? We recommend the University be diligent in performing secondary reviews to ensure the calculations are performed correctly along with review of Banner inputs to ensure the proper number of days are included in each term. Views of Responsible Officials and Planned Corrective Actions ?

In reviewing the two students in question, the students were calculated incorrectly due to a transposing of a date when calculating the number of days in the period of enrollment. These students were recalculated and the additional Federal Direct Loan funds were returned to the programs. In addition, all Fall students that withdrew were reviewed to make sure the transposing of the date did not affect their calculations. No additional students were found by Lewis University. The total liability of these two students was $225.00. As a result of this the Office of Financial Aid will implement a review process for the Return of Title IV funds to provide a checks and balance for this process to ensure that if these errors occur they will be caught before it becomes a compliance finding.

2019-003

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268. Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? Under the Pell grant and loan programs, universities must complete and return within 30 days the Enrollment Reporting roster file. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the University must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309). Condition ? Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required timeframe. Questioned Costs ? None. Context ? Out of a sample of 25 students from a population of 1,000 students who had changes in status during the year, NSLDS was not provided timely notification for 22 of the student status changes reviewed. Our sample was not, and was not intended to be, statistically valid. Effect ? NSLDS did not contain current information with respect to the student status of some students. Cause ? Information between the Clearinghouse and NSLDS was not updated timely. This could have been a result of the University?s data files not including the most recent information upon submission to the Clearinghouse. Identification as a Repeat Finding ? N/A Recommendation ? We recommend the University monitor and evaluate the scheduled reporting dates to the Clearinghouse. Also, confirm or modify existing formal policies, procedures or processes for timely identification or reporting lines that need to be informed to ensure that status changes can be communicated to NSLDS timely. Finally, we recommend the University implement a secondary review process to ensure those students with status changes are being properly reflected within NSLDS after the submission is received.

Views of Responsible Officials and Planned Corrective Actions ? The 22 students have been corrected in the NSLC and a one-time file was sent to NSLDS to update the student?s status. It was determined that Lewis University is sending a Degree file to the Clearinghouse instead of a Graduate only status file. The Degree file does not update a student?s graduation status and if not processed in a timely manner can result in a student appearing to have withdrawn instead of graduating. Lewis University will begin to send a Graduate status file to the Clearinghouse starting with the December 2019 graduates. In addition the Degree files will be reviewed for errors in order to avoid an inadvertent status on a student record. The Office of the Registrar has been in contact with the NSC Audit Resource Team who recommended the additional file submission and will continue to work with them to assure data integrity and file submission compliance. Additionally, the documentation from Ellucian will assist in training for the Office of the Registrar in creating this process.

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; TEACH Grant, CFDA 84.379; Federal Work-Study Program, CFDA 84.033; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; and Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement - Special Tests and Provisions - Disbursements to or on behalf of students Condition ? 34 CFR section 668.165 requires the University to notify student, or parent 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 to the holder of that loan; 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. Questioned Costs ? N/A Context ? A sample of 25 students was selected for testing out of a total population of 3,963 to determine written notifications were sent to students, or parents after disbursements. The University did not complete the required notifications for 25 of the students selected for testing. Our sample selection was not, and was not intended to be, statistically valid. Effect ? Students or parents were not notified of disbursements or notified of their right to cancel all or a portion of the loan disbursement. Cause ? Due to an oversight in the Financial Aid Department, these notifications were not sent during the 2019 fiscal year. Identification as a Repeating Finding ? N/A Recommendation ? The University should establish processes and controls to ensure disbursement notification letters are sent as required.

Views of Responsible Officials and Planned Corrective Actions ? Lewis University?s process for notifying students of their loan disbursements was the monthly student statements and email notifications of their availability. No prior audit raised concerns about the process that was utilized by Lewis University to meet this requirement. The current audit found this process to be insufficient and as a result Lewis University developed an email process which notifies students of their loan disbursement and the right to cancel that disbursement. This process was implemented beginning with the Summer 2019 disbursements. The email notifications are documented in the student?s Banner file on the date they are sent.

Federal Program ? Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, CFDA 84.063; TEACH Grant, CFDA 84.379; Federal Work-Study Program, CFDA 84.033; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; and Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Return of Title IV Funds ? 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 aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)). Condition ? The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University returned the incorrect amount of funds to the Department of Education because of the error in the calculation. Questioned Costs ? $41, Federal Direct Loans, CFDA 84.268 Context ? Of a sample of eight return of funds tested from a population of 79 performed during the examination period, three return of funds calculations were not performed correctly. This resulted in an incorrect amount of funds being returned to the Department of Education for three of those eight students. Our sample was not, and was not intended to be, statistically valid. Cause ? The number of days in the break for the Fall semester was calculated incorrectly when determining the enrollment period. Effect ? The University returned the incorrect amount of funds to the Department of Education. Identification as a Repeat Finding ? N/A Recommendation ? We recommend the University be diligent in performing secondary reviews to ensure the calculations are performed correctly along with review of Banner inputs to ensure the proper number of days are included in each term.

Views of Responsible Officials and Planned Corrective Actions ? The number of days in the term/module was incorrect in the Banner table and did not exclude the correct number of days for a break period. The Office of the Registrar has updated the Banner table to reflect the correct days in the term/module. In addition, the Office of Financial Aid Services has developed a secondary spreadsheet that hold those term dates and calculated the number of days in the term/module for verification. The Office of Financial Aid Services corrected the student?s R2T4 calculations and returned the appropriate dollars to the federal programs. In addition, all Fall 2018 R2T4 calculations were reviewed and corrected with the appropriate dollars returned to the federal programs.

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