EIN: 386007327
UEI: J7WULLYGFRH1
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 30, 2026 (39 days from today).
What is a management decision? →Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year Various Pass through Entity N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2024-001 Criteria - The University has 60 days from the date the University determines an enrollment status change to report to National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition - Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who withdrew whose status change was not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in an accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Western Michigan University has discontinued the use of manual enrollment status updates in the NSC Student Look Up tool for unofficial withdrawals. The Registrar’s Office now records last date of attendance and withdrawal status directly in the SIS for all students who earn all E and X grades and are determined to have unofficially withdrawn. All unofficial withdrawal records are included in the final enrollment submission for the term, ensuring that withdrawal status and effective dates are transmitted through certified batch files to NSC and NSLDS.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year Various Pass through Entity N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2024-001 Criteria - The University has 60 days from the date the University determines an enrollment status change to report to National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition - Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who withdrew whose status change was not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in an accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Western Michigan University has discontinued the use of manual enrollment status updates in the NSC Student Look Up tool for unofficial withdrawals. The Registrar’s Office now records last date of attendance and withdrawal status directly in the SIS for all students who earn all E and X grades and are determined to have unofficially withdrawn. All unofficial withdrawal records are included in the final enrollment submission for the term, ensuring that withdrawal status and effective dates are transmitted through certified batch files to NSC and NSLDS.
Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Root Cause: Manual NSC updates were overwritten by subsequent certified enrollment files. Planned Corrective Action: Western Michigan University has discontinued the use of manual enrollment status updates in the NSC Student Look-Up tool for unofficial withdrawals. The Registrar’s Office now records last date of attendance and withdrawal status directly in the SIS for all students who earn all E and X grades and are determined to have unofficially withdrawn. All unofficial withdrawal records are included in the final enrollment submission for the term, ensuring that withdrawal status and effective dates are transmitted through certified batch files to NSC and NSLDS. Contact person responsible for corrective action: Registrar, Carrie Cumming Assistant Registrar of Academic Records, Nicole Miller Anticipated Completion Date: 08/20/2025 (This is the day we sent summer II 2025 final enrollment to the NSC. Summer II 2025 LDA changes were completed directly into the SIS.)
2024-001
Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.220)(1)). Condition - Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - The University did not timely identify students that had loan disbursements but never attended. Out of our sample of 40 students who withdrew from the University, 3 students that never attended the University however received their accepted aid did not have returns completed within 30 days. Cause and Effect - The University's process to identify the students that never attended was not operating effectively and as a result the students were reported outside of the required timeframe. Recommendation - We recommend the University review its processes and controls for identifying students that enrolled but never attended to ensure a timely return of federal aid. Views of Responsible Officials and Planned Corrective Actions - Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associated reports, to monitor all types of student withdrawal and drop determinations, as well as the corresponding R2T4 deadlines. Standardized procedures and a comprehensive processing checklist will be developed to ensure accuracy and timely completion. Staff in both offices will be trained on the updated procedures. Financial Aid will also continue working with the Registrar’s Office to ensure the receipt of accurate and timely enrollment data necessary to meet all Title IV requirements and deadlines.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.220)(1)). Condition - Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - The University did not timely identify students that had loan disbursements but never attended. Out of our sample of 40 students who withdrew from the University, 3 students that never attended the University however received their accepted aid did not have returns completed within 30 days. Cause and Effect - The University's process to identify the students that never attended was not operating effectively and as a result the students were reported outside of the required timeframe. Recommendation - We recommend the University review its processes and controls for identifying students that enrolled but never attended to ensure a timely return of federal aid. Views of Responsible Officials and Planned Corrective Actions - Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associated reports, to monitor all types of student withdrawal and drop determinations, as well as the corresponding R2T4 deadlines. Standardized procedures and a comprehensive processing checklist will be developed to ensure accuracy and timely completion. Staff in both offices will be trained on the updated procedures. Financial Aid will also continue working with the Registrar’s Office to ensure the receipt of accurate and timely enrollment data necessary to meet all Title IV requirements and deadlines.
Condition: Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Planned Corrective Action: Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associated reports, to monitor all types of student withdrawal and drop determinations, as well as the corresponding R2T4 deadlines. Standardized procedures and a comprehensive processing checklist will be developed to ensure accuracy and timely completion. Staff in both offices will be trained on the updated procedures. Financial Aid will also continue working with the Registrar’s Office to ensure the receipt of accurate and timely enrollment data necessary to meet all Title IV requirements and deadlines. Contact person responsible for corrective action: Shashanta S James, Director Lana Greaves, Sr. Associate Director Anticipated Completion Date: April 15, 2026
FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year Various Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria The University has 60 days from the date the University determines an enrollment status change to report to National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Out of a sample of 40 students, our testing identified 5 students that were reported as withdrawn from the University with the improper enrollment effective date and 1 student that changed their address at the University and it was not reported to NSLDS. Cause and Effect The University did not have formal procedures and controls in place to determine the appropriate effective date of unofficial withdrawals or properly identify students that changed their address within the University's student information system and ensure these students were properly reported in the monthly enrollment roster. Recommendation The University should update their policy to align the definition of the enrollment effective date with the regulations and implement controls to ensure the appropriate data elements are complete, accurate, and timely prior to submission. Views of Responsible Officials and Corrective Action Plan To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22: • The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office. • The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date. • All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year Various Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria The University has 60 days from the date the University determines an enrollment status change to report to National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Out of a sample of 40 students, our testing identified 5 students that were reported as withdrawn from the University with the improper enrollment effective date and 1 student that changed their address at the University and it was not reported to NSLDS. Cause and Effect The University did not have formal procedures and controls in place to determine the appropriate effective date of unofficial withdrawals or properly identify students that changed their address within the University's student information system and ensure these students were properly reported in the monthly enrollment roster. Recommendation The University should update their policy to align the definition of the enrollment effective date with the regulations and implement controls to ensure the appropriate data elements are complete, accurate, and timely prior to submission. Views of Responsible Officials and Corrective Action Plan To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22: • The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office. • The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date. • All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester.
Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Planned Corrective Action: To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22: The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office. The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date. All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester. Contact person responsible for corrective action: Carrie Cumming, Registrar Anticipated Completion Date: July 2025
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster, 47.076, National Science Foundation, Education and Human Resources Federal Award Identification Number and Year - 1841783 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass through entity reasonably believes the request to be improper. Condition - Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Questioned Costs - None Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments on 3 samples ranged from 37 - 71 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Management agrees. The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day payment requirement. 2 of the payments were during the major service disruption of the entire university network. We have now implemented weekly backups to the network folders that contain our subrecipient monitoring files. 1 of the payments was due to the department not sending us the invoice timely. We plan to do follow up trainings to educate departments and PIs on the requirement for providing payment within 30 days of receipt of invoice to assure payment is made within the 30 day requirement.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster, 47.076, National Science Foundation, Education and Human Resources Federal Award Identification Number and Year - 1841783 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass through entity reasonably believes the request to be improper. Condition - Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Questioned Costs - None Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments on 3 samples ranged from 37 - 71 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Management agrees. The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day payment requirement. 2 of the payments were during the major service disruption of the entire university network. We have now implemented weekly backups to the network folders that contain our subrecipient monitoring files. 1 of the payments was due to the department not sending us the invoice timely. We plan to do follow up trainings to educate departments and PIs on the requirement for providing payment within 30 days of receipt of invoice to assure payment is made within the 30 day requirement.
Finding Number: 2023-001 Condition: Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Planned Corrective Action: The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day payment requirement. 2 of the payments were during the major service disruption of the entire university network. We have now implemented weekly backups to the network folders that contain our subrecipient monitoring files. 1 of the payments was due to the department not sending us the invoice timely. We plan to do follow up trainings to educate departments and PIs on the requirement for providing payment within 30 days of receipt of invoice to assure payment is made within the 30 day requirement. Contact person responsible for corrective action: Betty McKain, Sr Director Research Administration Anticipated Completion Date: 06/30/2024
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)) Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 8 students who graduated or withdrew whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely to NSLDS. As a result, certain student status changes were not reported to NSLDS in a timely manner. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided.
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of a status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)) Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 8 students who graduated or withdrew whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely to NSLDS. As a result, certain student status changes were not reported to NSLDS in a timely manner. Recommendation - The University should implement controls to ensure all student status changes are reported timely to NSLDS. Views of Responsible Officials and Corrective Action Plan - While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided.
Finding Number: 2022-001 Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: While the information was reported on time to the National Student Clearinghouse, there were unresolved error reports that prevented three of these students from being reported to NSLDS within the 60 days. For the other five students, there was a delay within the clearinghouse which was an isolated incident. We will continue to follow up with the clearinghouse and NSLDS for students that are not updated and staff responsible for reconciling error reports will notify a supervisor if they are unable to complete the task within two weeks so additional assistance can be provided. Contact person responsible for corrective action: Carrie Cumming, Registrar Anticipated Completion Date: 3/01/2023
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-001 Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 30 students with returns initiated after the required timing, ranging from 48 to 490 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely, and, as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by implementing more frequent review of withdrawal reports and holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations.
Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by: 1. Reviewing reports of withdrawn students on a daily basis. 2. Weekly reporting of R2T4 and LDA students and calculations with two levels of approvals. 3. Holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Aid Anticipated Completion Date: 10/23/2022
2021-001
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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 (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-002 Criteria - 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 (34 CFR 668.22). Condition - The University did not return funds in accordance with the above criteria. Questioned Costs - $36,158 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 40 students tested, there was 1 student who had a calculation performed but the aid was not returned, resulting in questioned costs of $3,558. In addition, of the 40 students tested, there were 4 students who did not have a calculation performed and therefore no aid was returned. As a result of additional testing, a total of 17 students (including the 4 from the original sample) that withdrew between October 27, 2021 and November 6, 2021 did not have a return of Title IV (R2T4) calculation performed. The University performed calculations for these 17 students, resulting in the additional questioned costs of $32,600. Cause and Effect - The University did not have proper controls in place to ensure funds were calculated and returned. For the first student, the University calculated the proper amount of aid to be returned, but due to human error the amount was not returned nor identified during review. Secondly, the University improperly determined the 60 percent withdrawal date as October 27, 2021 rather than the correct date of November 6, 2021 and did not identify any withdrawn students that period that required a R2T4 calculation and therefore did not return the appropriate aid. Recommendation - The University should implement controls to ensure Title IV refunds are calculated and returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on January 13, 2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term.
Finding Number: 2022-003 Condition: The University did not return funds in accordance with 34 CFR 668.22 which states, 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. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on 01-13-2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 04/15/2023
2021-002
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Finding Number: 2022-004 Condition: The University did not file accurate and timely reports throughout the fiscal year. Planned Corrective Action: 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required. Contact person responsible for corrective action: Colleen Scarff, Assoc VP for Business and Finance and Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 3/24/23
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.
Finding Number: 2022-005 Condition: The University improperly reported the students that withdrew within the COD System as a result of the COVID-19 national emergency. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 4/15/2023
FAC accepted this audit on July 11, 2022 — management decision was due January 11, 2023.
ALN, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Educational Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 10 students with returns calculated properly but initiated after the required timing, ranging from 46 to 91 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Corrective Action Plan - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. Management acknowledges the deficiencies are due to the lack of reports indicating when a student withdrew and a staffing shortage. In response to the finding, SFA has evaluated its R2T4 procedures and will strengthen its internal controls by implementing review of weekly reports, hiring new staff and temporary employees, training staff on the R2T4 process, holding monthly meetings, and implementing a self assessment process. Additionally, the SFA office recently hired an Associate Director of Compliance to ensure regulatory and administrative requirements for Title IV federal student aid programs. The Associate Director will periodically review R2T4 processes and procedures to ensure compliance, facilitate the monthly R2T4 meetings, and track and monitor R2T4 deadlines to ensure timely completion to manage and mitigate risk.
Show full finding ▾Hide full finding ▴ALN, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Educational Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic fund transfers initiated to ED as soon as possible but no later than 45 days after the date the institution determines that the student withdrew (34 CFR 668.173(b)). However, the institution must return those funds for which it is responsible as soon as possible but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR 668.21(b)). Condition - The University initiated certain returns of Title IV funds after the required timing. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 10 students with returns calculated properly but initiated after the required timing, ranging from 46 to 91 days after the withdrawal date. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and as a result, certain returns were after the required time period. Recommendation - The University should implement controls to ensure return of Title IV refunds are initiated timely. Views of Responsible Officials and Corrective Action Plan - The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds (R2T4) were initiated after the required time. Management acknowledges the deficiencies are due to the lack of reports indicating when a student withdrew and a staffing shortage. In response to the finding, SFA has evaluated its R2T4 procedures and will strengthen its internal controls by implementing review of weekly reports, hiring new staff and temporary employees, training staff on the R2T4 process, holding monthly meetings, and implementing a self assessment process. Additionally, the SFA office recently hired an Associate Director of Compliance to ensure regulatory and administrative requirements for Title IV federal student aid programs. The Associate Director will periodically review R2T4 processes and procedures to ensure compliance, facilitate the monthly R2T4 meetings, and track and monitor R2T4 deadlines to ensure timely completion to manage and mitigate risk.
Finding Number: 2021-001 Condition: The University initiated certain returns of Title IV funds after the required timing. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds were initiated after the required time. Management acknowledges the deficiencies are due to: 1. The lack of reports indicating when a student withdrew 2. A staffing shortage In response to the finding, SFA has evaluated its R2T4 procedures and will strengthen its internal controls by: 1. The availability and review of weekly reports to identify withdrawn students o The first report was generated on May 30, 2022 2. Hiring new staff and temporary employees 3. Training staff on the R2T4 process 4. Holding monthly meetings to: o Provide a secondary review of completed R2T4 calculations o Ensure all R2T4 calculations and returns are completed accurately and within the allowable timeframe o Track the number of days remaining to perform R2T4 calculations 5. Performing a self-assessment during the Fall and Spring terms by reviewing a random sample of student files to ensure the accurate and timely completion of the R2T4 process. Additionally, the SFA office recently hired an Associate Director of Compliance to ensure regulatory and administrative requirements for Title IV federal student aid programs. The Associate Director will periodically review R2T4 processes and procedures to ensure compliance, facilitate the monthly R2T4 meetings, and track and monitor R2T4 deadlines to ensure timely completion to manage and mitigate risk. Contact person responsible for corrective action: Senior Associate Director, Student Financial Aid Anticipated Completion Date: 06/16/2022
ALN, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 their behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return all of the funds calculated to be returned for a student. Questioned Costs - $1,732 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 25 students tested, there was 1 student with the incorrect amount of aid returned. Cause and Effect - The University calculated the proper amount of aid to be returned and attempted to return the aid; however, there was an error in initiating the return within the student information system, causing the aid to not be returned. The University attempted to follow up on the error but because of staffing shortages and the pandemic, the aid was ultimately not returned. The University did not have a control in place to ensure that the aid was actually returned for this student. Recommendation - The University should implement controls to ensure Title IV refunds are returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Our review confirmed all other aid for the student was billed back successfully. However, the $1,732 unsubsidized loan that was attempted to be returned but did not transmit to COD due to a staff initiated change to the NSLDS review status code in our ERP system, Banner. Unaware of an update to the NSLDS review status code, another staff member attempted to return the aid and opened an internal help ticket after realizing the $1,732 could not be returned. The ticket was closed prematurely and without appropriate follow up to ensure the return could occur. Management acknowledges a deficiency in the staff?s understating of Banner NSLDS review status codes, their impact on returns, and the need to follow up on help tickets. In response to the finding, SFA will evaluate its Banner NSLDS review status code and help ticket procedures, and will strengthen its processes by training staff, testing resting resolved ticket issues before assigning a closed status, and following up on help tickets. The isolated occurrence was corrected on June 16, 2022.
Show full finding ▾Hide full finding ▴ALN, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 their behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs (34 CFR 668.22). Condition - The University did not return all of the funds calculated to be returned for a student. Questioned Costs - $1,732 Identification of How Questioned Costs Were Computed - The amount of aid that was not returned. Context - Of the 25 students tested, there was 1 student with the incorrect amount of aid returned. Cause and Effect - The University calculated the proper amount of aid to be returned and attempted to return the aid; however, there was an error in initiating the return within the student information system, causing the aid to not be returned. The University attempted to follow up on the error but because of staffing shortages and the pandemic, the aid was ultimately not returned. The University did not have a control in place to ensure that the aid was actually returned for this student. Recommendation - The University should implement controls to ensure Title IV refunds are returned appropriately. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Our review confirmed all other aid for the student was billed back successfully. However, the $1,732 unsubsidized loan that was attempted to be returned but did not transmit to COD due to a staff initiated change to the NSLDS review status code in our ERP system, Banner. Unaware of an update to the NSLDS review status code, another staff member attempted to return the aid and opened an internal help ticket after realizing the $1,732 could not be returned. The ticket was closed prematurely and without appropriate follow up to ensure the return could occur. Management acknowledges a deficiency in the staff?s understating of Banner NSLDS review status codes, their impact on returns, and the need to follow up on help tickets. In response to the finding, SFA will evaluate its Banner NSLDS review status code and help ticket procedures, and will strengthen its processes by training staff, testing resting resolved ticket issues before assigning a closed status, and following up on help tickets. The isolated occurrence was corrected on June 16, 2022.
Finding Number: 2021-002 Condition: The University did not return all of the funds calculated to be returned for a student. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Our review confirmed all other aid for the student was billed back successfully. However, the $1,732 unsubsidized loan that was attempted to be returned but did not transmit to COD due to a staff-initiated change to the NSLDS review status code in our ERP system, Banner. Unaware of an update to the NSLDS review status code, another staff member attempted to return the aid and opened an internal help ticket after realizing the $1,732 could not be returned. The ticket was closed prematurely and without appropriate follow-up to ensure the return could occur. Management acknowledges a deficiency in the staff?s understating of Banner NSLDS review status codes, their impact on returns, and the need to follow up on help tickets. In response to the finding, SFA will evaluate its Banner NSLDS review status code and help ticket procedures, and will strengthen its processes by: 1. Training staff on the impact Banner NSLDS review status codes updates on aid 2. Testing resolved help ticket issues before assigning a closed status 3. Following up on help tickets by confirming the return of funds on a student?s account balance The isolated occurrence was corrected on 06-16-2022. The $1,732 unsubsidized loan was returned and the change is reflected in COD. SFA awarded the student institutional aid of $1,732 to compensate for the error. Contact person responsible for corrective action: Senior Associate Director, Student Financial Aid Anticipated Completion Date: 07/15/2022
FAC accepted this audit on June 21, 2021 — management decision was due December 21, 2021.
CFDA Number, Federal Agency, and Program Name - 84.425F, U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund Finding Type - Significant deficiency Repeat Finding - No Criteria - Allowable expenditures must be to cover any costs associated with significant changes to the delivery of instruction due to the coronavirus (CARES Act Section 18004(c)). Condition - Housing and dining refunds were disbursed to 20 students who were determined not to be eligible to receive a refund based on the University's established refund policy, resulting in unallowable costs. Questioned Costs - $16,840 Identification of How Questioned Costs Were Computed - Questioned costs were determined by accumulating all housing and dining refunds received by the 20 students who were determined to not be eligible. Context During our initial testing, we noted 1 of 11 students was determined to have received the refund in error based on the University's policy and in accordance with the CARES Act. Based upon further review of refunds to students, an additional 19 students were determined to be ineligible for the refund. Approximately 3,900 students received housing and dining refunds. Cause and Effect - The students received the housing and dining refunds in error, which resulted in unallowable costs, as the students were ineligible based on the University's established refund policy. Recommendation - A review process should be implemented to ensure students are eligible for a housing and dining refund before awards are processed. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. Although it is unlikely that this process would be utilized moving forward, internal controls will be implemented to ensure that future refunds of this nature are disbursed according to the guidelines set forth. Moving forward, housing will continue to generate the batch list of students that will receive the credit. As an added step, student affairs business operations will verify the list against documentation collected by residence life that indicates the student's eligibility to receive the refund. If a student appears on the batch list for the refund, but does not appear to meet the eligibility requirements, the credit will be further discussed with housing, and the student will be eliminated from the batch list if determined necessary. This additional verification process should serve to eliminate future issues.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - 84.425F, U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund Finding Type - Significant deficiency Repeat Finding - No Criteria - Allowable expenditures must be to cover any costs associated with significant changes to the delivery of instruction due to the coronavirus (CARES Act Section 18004(c)). Condition - Housing and dining refunds were disbursed to 20 students who were determined not to be eligible to receive a refund based on the University's established refund policy, resulting in unallowable costs. Questioned Costs - $16,840 Identification of How Questioned Costs Were Computed - Questioned costs were determined by accumulating all housing and dining refunds received by the 20 students who were determined to not be eligible. Context During our initial testing, we noted 1 of 11 students was determined to have received the refund in error based on the University's policy and in accordance with the CARES Act. Based upon further review of refunds to students, an additional 19 students were determined to be ineligible for the refund. Approximately 3,900 students received housing and dining refunds. Cause and Effect - The students received the housing and dining refunds in error, which resulted in unallowable costs, as the students were ineligible based on the University's established refund policy. Recommendation - A review process should be implemented to ensure students are eligible for a housing and dining refund before awards are processed. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. Although it is unlikely that this process would be utilized moving forward, internal controls will be implemented to ensure that future refunds of this nature are disbursed according to the guidelines set forth. Moving forward, housing will continue to generate the batch list of students that will receive the credit. As an added step, student affairs business operations will verify the list against documentation collected by residence life that indicates the student's eligibility to receive the refund. If a student appears on the batch list for the refund, but does not appear to meet the eligibility requirements, the credit will be further discussed with housing, and the student will be eliminated from the batch list if determined necessary. This additional verification process should serve to eliminate future issues.
Finding Number: 2020-001 Condition: Housing and dining refunds were disbursed to twenty students who were determined not to be eligible to receive a refund based on the University's established refund policy, resulting in unallowable costs. Planned Corrective Action: Although it is unlikely that this process would be utilized moving forward, internal controls will be implemented to ensure that future refunds of this nature are disbursed according to the guidelines set forth. Moving forward, housing will continue to generate the batch list of students that will receive the credit. As an added step, Student Affairs Business Operations will verify the list against documentation collected by Residence Life that indicates the student?s eligibility to receive the refund. If a student appears on the batch list for the refund, but does not appear to meet the eligibility requirements, the credit will be further discussed with housing and the student will be eliminated from the batch list if determined necessary. This additional verification process should serve to eliminate future issues. Contact person responsible for corrective action: Nicole Kalmbach Anticipated Completion Date: 5/6/21
CFDA Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Student Financial Assistance Cluster Federal Direct Student Loans Finding Type - Significant deficiency Repeat Finding - No Criteria - The University is required to perform monthly reconciliations of federal funding between the Department of Education's records and the University's records. The University is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Condition - During our review of internal controls and testing procedures, it was noted that the monthly reconciliations were performed for certain months but not all months during the fiscal year, and there is no formal review process. Questioned Costs - None Context - Two of the three reconciliations selected for testing were not supported or reviewed due to reconciliations not being performed each month. Cause and Effect - The lack of performing and reviewing monthly reconciliations could lead to differences between the Department of Education and the University that could go unidentified for a period of time. Recommendation - We recommend that policies be put in place to ensure reconciliations are performed and reviewed on a monthly basis. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. Student financial aid will ensure monthly direct loan reconciliation is completed by instituting a series of checks and balances that includes the associate director of direct loans and the senior associate director. We will implement the following checks and balances that include completion date accountability, overhaul of written policies and procedures, and documented completion of monthly reconciliation. Monthly federal direct loan reconciliation with business and finance, financial aid, G5, and COD reviews for accuracy of expenditures and returns. Corrective action plans will start immediately with the full anticipation of a 12 month or full federal direct loan aid cycle to ensure full compliance.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Student Financial Assistance Cluster Federal Direct Student Loans Finding Type - Significant deficiency Repeat Finding - No Criteria - The University is required to perform monthly reconciliations of federal funding between the Department of Education's records and the University's records. The University is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Condition - During our review of internal controls and testing procedures, it was noted that the monthly reconciliations were performed for certain months but not all months during the fiscal year, and there is no formal review process. Questioned Costs - None Context - Two of the three reconciliations selected for testing were not supported or reviewed due to reconciliations not being performed each month. Cause and Effect - The lack of performing and reviewing monthly reconciliations could lead to differences between the Department of Education and the University that could go unidentified for a period of time. Recommendation - We recommend that policies be put in place to ensure reconciliations are performed and reviewed on a monthly basis. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. Student financial aid will ensure monthly direct loan reconciliation is completed by instituting a series of checks and balances that includes the associate director of direct loans and the senior associate director. We will implement the following checks and balances that include completion date accountability, overhaul of written policies and procedures, and documented completion of monthly reconciliation. Monthly federal direct loan reconciliation with business and finance, financial aid, G5, and COD reviews for accuracy of expenditures and returns. Corrective action plans will start immediately with the full anticipation of a 12 month or full federal direct loan aid cycle to ensure full compliance.
Finding Number: 2020-002 Condition: During our review of internal controls and testing procedures, it was noted that the monthly reconciliations were performed for certain months but not all months during the fiscal year and there is no formal review process. Planned Corrective Action: Student Financial Aid will ensure monthly Direct Loan reconciliation is completed by instituting a series of checks and balances that includes the Associate Director of Direct Loans and the Senior Associate Director. We will implement the following checks and balances that include completion date accountability, overhaul of written policies and procedures, and documented completion of monthly reconciliation. Monthly Federal Direct Loan reconciliation with Business and Finance, Financial Aid, G5 and COD reviews for accuracy of expenditures and returns. Corrective action plans will start immediately with the full anticipation of a 12 month or full Federal Direct loan aid cycle to ensure full compliance. Contact person responsible for corrective action: Jodie Laraway/Steven Foster Anticipated Completion Date: 6/30/2022
FAC accepted this audit on January 2, 2019 — management decision was due July 2, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on February 2, 2017 — management decision was due August 2, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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