EIN: 410518750
UEI: ZTXJXKXGF5S3
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 17, 2025. 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 June 17, 2026 (72 days ago).
What is a management decision? →During our testing, we noted for 2 out of 40 students, the change in status was not reported timely. Questioned Costs: None Context: During our testing, we noted Mitchell Hamline School of Law’s current procedures did not operate effectively to verify student status changes were reported timely. Cause: The notification of status change was erroneously sent to the wrong Mitchell Hamline email, so the Financial Aid office was not aware of this student's change in a timely manner. Effect: Mitchell Hamline School of Law did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No. Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted for 2 out of 40 students, the change in status was not reported timely. Questioned Costs: None Context: During our testing, we noted Mitchell Hamline School of Law’s current procedures did not operate effectively to verify student status changes were reported timely. Cause: The notification of status change was erroneously sent to the wrong Mitchell Hamline email, so the Financial Aid office was not aware of this student's change in a timely manner. Effect: Mitchell Hamline School of Law did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No. Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.
Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Starting in January 2026, the Registrar’s Office will be performing the monthly reporting. In preparation for this change in responsibilities, Student Financial Aid has provided training to multiple individuals in the Registrar’s Office along with detailed documented procedures. Student Financial Aid and the Registrar’s Office will coordinate responses/requests from NSLDS. Name(s) of the contact person(s) responsible for corrective action: Sheila Tolley, Executive Registrar and Nick Anderson, Director of Financial Aid Planned completion date for corrective action plan: Spring Semester 2026
FAC accepted this audit on December 15, 2022 — management decision was due June 15, 2023.
Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2022-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2021?2022 Condition: Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2022-001 Finding: Three student?s enrollment changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Corrective Actions Taken or Planned: MHSL has hired an outside consultant through Agilyx to create a new enrollment report that will more accurately track and report the enrollment statuses for all students. MHSL will be using this report starting Fall 2022. The Director of Financial Aid now completes enrollment reporting. For each report, students will be selected by Director at random to manually review. Assistant Director of Financial Aid will also select a group at random to review for accuracy. This way both the person who runs the report and a person who does not will review a random sample of students. Also, additional scheduled date for enrollment reporting have been added to the school transmission schedule including j Term and summer. This will prevent late reporting over the summer. Contact Person: Lynn LeMoine ? Dean of Students; Katie Kuehl ? Registrar; and Nick Anderson ? Financial Aid Director. Anticipated Completion Date: Fall 2022
2021-001
While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2022-002 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) Subprograms Section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2022-02 Finding: HEERF Activities Allowed or Unallowed While testing activities allowed or unallowed in the audit of 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Corrective Actions Taken or Planned: School now has a documented plan on file for disbursing HEERF funds. Contact Person: Lynn LeMoine Dean of Students ? Nick Anderson Director of Financial Aid Anticipated Completion Date: 4/11/2022
2021-005
While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing student needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Two out of two reports tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2022-003 HEERF Reporting U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing student needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Two out of two reports tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2022-003 Finding: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Corrective Actions Taken or Planned: Student funds for HEERF have been exhausted so no additional reporting should be required for them. For all institutional HEERF funds reporting, both the Financial Aid Director and the Controller review the information and complete the Institutional reporting PDF. Once posted, the PDF is emailed to the Department of Educations as a time stamp to show it was completed on time. Contact Person: Nick Anderson Director of Financial Aid ? Deb Kessler Controller Anticipated Completion Date: 7/10/2022
2021-004
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
The School submits batch uploads to the National Student Loan Data System (NSLDS) on a monthly basis and makes adjustments in between submissions directly via the NSLDS website. While testing Enrollment Reporting, it was noted: 1. Student status change was reported to the NSLDS enrollment database after the required 60-day enrollment certification requirement; 2. Students reported effective enrollment date was reported inaccurately; 3. Students program enrollment status was reported inaccurately; and 4. Roster error files received from NSLDS had errors that were not corrected timely. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Schools must complete and return within 15 days the enrolment reporting roster file. After the school submits the enrollment reporting roster to NSLDS, NSLDS evaluates the roster and provides the school an error/acknowledgement file. Per NSLDS Enrollment Reporting Guide 5.1, if errors are identified, schools have 10 days to correct the errors and resubmit to NSLDS. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. Enrollment reports were submitted to the National Student Clearinghouse (NSC) by the Office of the Registrar. Financial Aid office also submitted a single update to NSLDS. The error resolution through NSC was submitted timely, but errors generated via the Financial Aid update to NSLDS conflicted with NSC reports and the errors were not timely resolved. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Prevalence of errors is presented below: 1. Four out of 61 students tested. 2. One out of 61 students tested. 3. One out of 61 students tested. 4. Three of 12 monthly rosters tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2020?2021 Condition: The School submits batch uploads to the National Student Loan Data System (NSLDS) on a monthly basis and makes adjustments in between submissions directly via the NSLDS website. While testing Enrollment Reporting, it was noted: 1. Student status change was reported to the NSLDS enrollment database after the required 60-day enrollment certification requirement; 2. Students reported effective enrollment date was reported inaccurately; 3. Students program enrollment status was reported inaccurately; and 4. Roster error files received from NSLDS had errors that were not corrected timely. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Schools must complete and return within 15 days the enrolment reporting roster file. After the school submits the enrollment reporting roster to NSLDS, NSLDS evaluates the roster and provides the school an error/acknowledgement file. Per NSLDS Enrollment Reporting Guide 5.1, if errors are identified, schools have 10 days to correct the errors and resubmit to NSLDS. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. Enrollment reports were submitted to the National Student Clearinghouse (NSC) by the Office of the Registrar. Financial Aid office also submitted a single update to NSLDS. The error resolution through NSC was submitted timely, but errors generated via the Financial Aid update to NSLDS conflicted with NSC reports and the errors were not timely resolved. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Prevalence of errors is presented below: 1. Four out of 61 students tested. 2. One out of 61 students tested. 3. One out of 61 students tested. 4. Three of 12 monthly rosters tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2021-001 Finding: The School submits batch uploads to the National Student Loan Data System (NSLDS) on a monthly basis and makes adjustments in between submissions directly via the NSLDS website. While testing Enrollment Reporting, it was noted: ? Student status change was reported to the NSLDS enrollment database after the required 60-day enrollment certification requirement; ? Students reported effective enrollment date was reported inaccurately; ? Student?s program enrollment status was reported inaccurately; and ? Roster error files received from NSLDS had errors that were not correctly timely. Corrective Actions Taken or Planned: MHSL has hired an outside consultant through Agilyx to create a new enrollment report that will more accurately track and report the enrollment statuses for all students. MHSL will be using this report starting Fall 2022. The Director of Financial Aid now completes enrollment reporting. For each report, students will be selected by Director at random to manually review. Assistant Director of Financial Aid will also select a group at random to review for accuracy. This way both the person who runs the report and a person who does not will review a random sample of students. Also, additional scheduled date for enrollment reporting have been added to the school transmission schedule including j Term and summer. This will prevent late reporting over the summer. Contact Person: Lynn LeMoine ? Dean of Students; Katie Kuehl ? Registrar; and Nick Anderson ? Financial Aid Director. Anticipated Completion Date: Fall 2022
2020-001
While testing Return of Title IV Funds and Withdrawals, it was noted: 1. A student?s withdrawal date was not accurately recorded, and therefore, the School did not originally perform a return of Title IV funds calculation. This resulted in unearned funds not being returned within the required timeframe; 2. Students? period of enrollment calculation was not accurately performed by the School, resulting in an incorrect amount of unearned funds being returned and an amount was not returned within the required timeframe; and 3. A student?s return to Title IV funds calculation was completed correctly; however, a clerical error occurred when submitting the unearned funds resulting in an incorrect amount being returned and the amount was not returned in within the required timeframe. Criteria: Per 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from a school during a payment period or period of enrollment in which the recipient began attendance, the school must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date. Per 34 CFR 668.22(j), a school must always return any unearned Title IV funds it is responsible for returning within 45 days of the date the school determined the student withdrew. Cause: Management did not have effective internal controls in place to ensure that compliance with return of Title IV funds requirements were followed. In one case, an incorrect date was used due to lack of appropriate communication within departments at the School and in the other cases, errors were made in either the calculation or the data entry involved in the remittance process. Effect: The amount of unearned Federal Direct Loan Funds was not properly determined and/or remitted to the Department of Education within 45 days of the School determining that the student withdrew. Prevalence: Prevalence of errors is presented below: 1. One out of 13 students tested. 2. Two out of 13 students tested. 3. One out of 13 students tested. Questioned costs: 1. $4,504 2. $87 3. $50 Repeat finding?: Yes. Recommendation: Management should strengthen controls for return of Title IV Funds calculations and should ensure that funds are being properly returned within the 45-day required time frame. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-002 Return of Title IV Funds U.S. Department of Education Program Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Award Year: 2020?2021 Condition: While testing Return of Title IV Funds and Withdrawals, it was noted: 1. A student?s withdrawal date was not accurately recorded, and therefore, the School did not originally perform a return of Title IV funds calculation. This resulted in unearned funds not being returned within the required timeframe; 2. Students? period of enrollment calculation was not accurately performed by the School, resulting in an incorrect amount of unearned funds being returned and an amount was not returned within the required timeframe; and 3. A student?s return to Title IV funds calculation was completed correctly; however, a clerical error occurred when submitting the unearned funds resulting in an incorrect amount being returned and the amount was not returned in within the required timeframe. Criteria: Per 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from a school during a payment period or period of enrollment in which the recipient began attendance, the school must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date. Per 34 CFR 668.22(j), a school must always return any unearned Title IV funds it is responsible for returning within 45 days of the date the school determined the student withdrew. Cause: Management did not have effective internal controls in place to ensure that compliance with return of Title IV funds requirements were followed. In one case, an incorrect date was used due to lack of appropriate communication within departments at the School and in the other cases, errors were made in either the calculation or the data entry involved in the remittance process. Effect: The amount of unearned Federal Direct Loan Funds was not properly determined and/or remitted to the Department of Education within 45 days of the School determining that the student withdrew. Prevalence: Prevalence of errors is presented below: 1. One out of 13 students tested. 2. Two out of 13 students tested. 3. One out of 13 students tested. Questioned costs: 1. $4,504 2. $87 3. $50 Repeat finding?: Yes. Recommendation: Management should strengthen controls for return of Title IV Funds calculations and should ensure that funds are being properly returned within the 45-day required time frame. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2021-002 Finding: While testing Return of Title IV Funds and Withdrawals, it was noted: ? A student?s withdrawal date was not accurately recorded, and therefore, the School did not originally perform a return of Title IV funds calculation. This resulted in unearned funds not being returned within the required timeframe; ? Students? period of enrollment calculation was not accurately performed by the School, resulting in an incorrect amount of unearned funds being returned and an amount was not returned within the required timeframe; and ? A student?s return to Title IV funds calculation was completed correctly; however, a clerical error occurred when submitting the unearned funds resulting in an incorrect amount being returned and the amount was not returned in within the required timeframe. Corrective Actions Taken or Planned: The School has changed it attendance policy to be a school that is required to take attendance. As a result, a new process has been implemented to determine a student?s Last Day of Attendance (LDA). When a student withdraws, the Dean of Students requests support from the student?s instructors as well as Canvas (online student interface) to determine the student?s documented LDA. This information is shared with the Director of Financial Aid to review and confirm before withdrawal paperwork is submitted. As a result, there are multiple people reviewing and confirming the LDA. The Financial Aid Department now completes the R2T4 instead of Student Accounts. This is now completed electronically on Commonline Origination and Disbursement (COD). This will prevent any clerical errors and typos. The Financial Aid office also reviews and approves the refund schedules used for R2T4 and can pre-populate them in COD to prevent data errors. The Assistant Director of Financial Aid creates the refunds scales, and the Director of Financial Aid approves. Likewise, the R2T4 is completed by the Assistant Director of Financial Aid and then approved by the Director of Financial Aid. Contact Person: Lynn LeMoine Dean of Students ? Nick Anderson Director of Financial Aid Anticipated Completion Date: Fall 2021
2020-002
While testing perkins loan recordkeeping and record retention, it was noted that the School could not provide the master promissory note for two of the loans tested. Criteria: Per 34 CFR 674.19 (e)(2)(i), an institution shall retain a record of disbursements for each loan made to a borrower on a master promissory note. Cause: Management did not have effective internal controls in place to ensure that compliance with Perkins loan recordkeeping and record retention were followed. The cause of the missing master promissory notes is unknown. Effect: The master promissory note is a necessary document related to the right for the Perkins loan to be collected and necessary for loans in default to be assigned to the Department of Education. Without this support it is possible that the loan could become uncollectible and unable to be assigned to the Department of Education. Prevalence: Two out of 45 master promissory notes tested. Questioned costs: None. Repeat finding?: No. Recommendation: Management should conduct an inventory of documentation of outstanding loans and make efforts to locate missing master promissory notes. If the notes cannot be found, the school should prepare alternative documentation to substantiate that the debt was made by the school and that the borrower acknowledges the debt, such as evidence of payment, requests for deferment or forbearance, etc. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-003 Perkins Loan Recordkeeping and Record Retention U.S. Department of Education Program Student Financial Assistance Programs Cluster Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2020?2021 Condition: While testing perkins loan recordkeeping and record retention, it was noted that the School could not provide the master promissory note for two of the loans tested. Criteria: Per 34 CFR 674.19 (e)(2)(i), an institution shall retain a record of disbursements for each loan made to a borrower on a master promissory note. Cause: Management did not have effective internal controls in place to ensure that compliance with Perkins loan recordkeeping and record retention were followed. The cause of the missing master promissory notes is unknown. Effect: The master promissory note is a necessary document related to the right for the Perkins loan to be collected and necessary for loans in default to be assigned to the Department of Education. Without this support it is possible that the loan could become uncollectible and unable to be assigned to the Department of Education. Prevalence: Two out of 45 master promissory notes tested. Questioned costs: None. Repeat finding?: No. Recommendation: Management should conduct an inventory of documentation of outstanding loans and make efforts to locate missing master promissory notes. If the notes cannot be found, the school should prepare alternative documentation to substantiate that the debt was made by the school and that the borrower acknowledges the debt, such as evidence of payment, requests for deferment or forbearance, etc. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2021-003 Finding: While testing Perkins loan recordkeeping and record retention, it was noted that the school could not provide the aster promissory note for two of the loans tested. While testing Perkins loan recordkeeping and record retention, it was noted School could not provide the master promissory note for two of the loans tested. Corrective Actions Taken or Planned: As the Perkins loan plan is winding down, the School will continue to work on completing student file audits for reassignment purposes. Contact Person: Deb Kessler, Controller Anticipated Completion Date: Spring 2023
While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. In addition, we noted: 1. Institutional reports did not match the amount reported on the Schedule of Expenditures of Federal Awards (SEFA); and 2. Documentation to support the date of the upload with the required reporting timeline was not maintained. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." In addition, recipients of HEERF funding must post aggregate amounts spent for each quarterly reporting period no later than 10 days after the end of each calendar quarter. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing students' needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: 1. One out of five reports tested. 2. Two out of five reports tested. Questioned costs: None. Repeat finding?: No. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-004 HEERF Reporting U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) COVID-19 Higher Education Emergency Relief Fund (HEERF) Fund for the Improvement of Postsecondary Education (FIPSE) Formula Grant (ALN 84.425N) Federal Award Year: 2020?2021 Condition: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. In addition, we noted: 1. Institutional reports did not match the amount reported on the Schedule of Expenditures of Federal Awards (SEFA); and 2. Documentation to support the date of the upload with the required reporting timeline was not maintained. Criteria: Per 2 CFR part 200.303, ?the non-Federal entity must: a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Effective internal controls should include procedures in place to ensure the proper reviews and approvals are performed over required reporting. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." In addition, recipients of HEERF funding must post aggregate amounts spent for each quarterly reporting period no later than 10 days after the end of each calendar quarter. Cause: Management did not have effective internal controls in place to ensure that reviews and approvals were performed over the reports due to the newness of the program. In addition, management placed more focus on addressing students' needs instead of implementing controls over reporting. Effect: Effective internal control over reporting was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: 1. One out of five reports tested. 2. Two out of five reports tested. Questioned costs: None. Repeat finding?: No. Recommendation: Management should establish and maintain controls over reporting. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2021-004 Finding: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. In addition, we noted: ? Institutional reports did not match the amount reported on the Schedule of Expenditures of Federal Awards (SEFA); and ? Documentation to support the date of the upload with the required reporting timeline was not maintained. Corrective Actions Taken or Planned: Student funds for HEERF have been exhausted so no additional reporting should be required for them. For all institutional HEERF funds reporting, both the Financial Aid Director and the Controller review the information and complete the Institutional reporting PDF. Once posted, the PDF is emailed to the Department of Educations as a time stamp to show it was completed on time. Contact Person: Nick Anderson Director of Financial Aid ? Deb Kessler Controller Anticipated Completion Date: 7/10/2022
While testing activities allowed or unallowed, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: No. Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-005 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) subprograms section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) COVID-19 Higher Education Emergency Relief Fund (HEERF) Fund for the Improvement of Postsecondary Education (FIPSE) Formula Grant (ALN 84.425N) Federal Award Year: 2020?2021 Condition: While testing activities allowed or unallowed, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: No. Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2021-005 Finding: HEERF Activities Allowed or Unallowed While testing activities allowed or unallowed, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds. Corrective Actions Taken or Planned: School now has a documented plan on file for disbursing HEERF funds. Contact Person: Lynn LeMoine Dean of Students ? Nick Anderson Director of Financial Aid Anticipated Completion Date: 4/11/2022
FAC accepted this audit on July 5, 2021 — management decision was due January 5, 2022.
The School submits batch uploads to the National Student Loan Data System (NSLDS) on a monthly basis, and makes adjustments in between submissions directly via the NSLDS website. While testing Enrollment Reporting, it was noted: 1. A student?s withdrawal was reported to the NSLDS enrollment database after the required 60-day enrollment certification requirement; 2. Some students? reported effective enrollment date was reported inaccurately; 3. A student?s program type and begin date for the period from which they withdrew was reported inaccurately; 4. Roster error files received from NSLDS had errors that were not corrected timely; and 5. Some students initially reported as withdrawn were not timely or accurately reported as graduated after graduated status was confirmed. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, Schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, Schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Schools must complete and return within 15 days the enrolment reporting roster file. After the School submits the enrollment reporting roster to NSLDS, NSLDS evaluates the roster and provides the School an error/acknowledgement file. Per NSLDS Enrollment Reporting Guide 5.1, if errors are identified, Schools have 10 days to correct the errors and resubmit to NSLDS. Per NSLDS Enrollment Reporting Guide 4.4.2, ?reporting the `W? as soon as it occurs ensures the timely movement of loans into repayment?It is important to note that, for a student who has graduated, Schools who initially report a withdraw must subsequently report the student as having graduated by certifying a `G? status at the campus-level and/or program-level as appropriate?The graduated status may protect the interest subsidy on the student?s current loans.? Additionally, per 4.4.3, ?An School must correctly report students who have completed a program with a `G? for ?Graduated? status rather than a `W? for ?Withdrawn?. Further, an accurate anticipated completion date aids in correct servicing of a student?s loans, avoiding unnecessary early conversion to repayment or too late conversion, causing technical defaults.? Cause: Inaccurate and untimely reporting of enrollment changes was the result of late adjustments to final determined withdrawal dates and miscommunication of the date of last attendance. Delay in graduated status reporting is due to delays in the School?s graduation processing. Enrollment reports were submitted to the National Student Clearinghouse (NSC) by the Office of the Registrar. Financial Aid submitted a single update to NSLDS. The error resolution through NSC was submitted timely, but errors generated via the Financial Aid update to NSLDS conflicted with NSC reports and thus errors were not timely resolved. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another School and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Prevalence of errors is presented below: 1. One out of 40 students had their enrollment status change reported to NSLDS outside of the 60-day window; 2. Six out of 40 students had their enrollment effective date reported to NSLDS inaccurately; 3. Three out of 40 students had the term and withdrawal effective date reported to NSLDS inaccurately; 4. Eight of 12 monthly rosters returned by NSLDS due to errors were not corrected and resubmitted within the 10-day period; and 5. Two out of 40 students tested did not have their enrollment status in the NSLDS database timely or accurately updated from `W? to `G? once the correct effective date was determined. Questioned costs: None Repeat finding?: No Recommendation: Management should review the controls and procedures in place to verify that accurate, timely, and complete data is being submitted to NSLDS. This should include separation of preparation, review, and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2020-001 Enrollment Reporting U.S. Department of Education Program Student Financial Assistance Programs Cluster Federal Direct Student Loans (CFDA 84.268) Federal Award Year: 2019?2020 Condition: The School submits batch uploads to the National Student Loan Data System (NSLDS) on a monthly basis, and makes adjustments in between submissions directly via the NSLDS website. While testing Enrollment Reporting, it was noted: 1. A student?s withdrawal was reported to the NSLDS enrollment database after the required 60-day enrollment certification requirement; 2. Some students? reported effective enrollment date was reported inaccurately; 3. A student?s program type and begin date for the period from which they withdrew was reported inaccurately; 4. Roster error files received from NSLDS had errors that were not corrected timely; and 5. Some students initially reported as withdrawn were not timely or accurately reported as graduated after graduated status was confirmed. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, Schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, Schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Schools must complete and return within 15 days the enrolment reporting roster file. After the School submits the enrollment reporting roster to NSLDS, NSLDS evaluates the roster and provides the School an error/acknowledgement file. Per NSLDS Enrollment Reporting Guide 5.1, if errors are identified, Schools have 10 days to correct the errors and resubmit to NSLDS. Per NSLDS Enrollment Reporting Guide 4.4.2, ?reporting the `W? as soon as it occurs ensures the timely movement of loans into repayment?It is important to note that, for a student who has graduated, Schools who initially report a withdraw must subsequently report the student as having graduated by certifying a `G? status at the campus-level and/or program-level as appropriate?The graduated status may protect the interest subsidy on the student?s current loans.? Additionally, per 4.4.3, ?An School must correctly report students who have completed a program with a `G? for ?Graduated? status rather than a `W? for ?Withdrawn?. Further, an accurate anticipated completion date aids in correct servicing of a student?s loans, avoiding unnecessary early conversion to repayment or too late conversion, causing technical defaults.? Cause: Inaccurate and untimely reporting of enrollment changes was the result of late adjustments to final determined withdrawal dates and miscommunication of the date of last attendance. Delay in graduated status reporting is due to delays in the School?s graduation processing. Enrollment reports were submitted to the National Student Clearinghouse (NSC) by the Office of the Registrar. Financial Aid submitted a single update to NSLDS. The error resolution through NSC was submitted timely, but errors generated via the Financial Aid update to NSLDS conflicted with NSC reports and thus errors were not timely resolved. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another School and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Prevalence of errors is presented below: 1. One out of 40 students had their enrollment status change reported to NSLDS outside of the 60-day window; 2. Six out of 40 students had their enrollment effective date reported to NSLDS inaccurately; 3. Three out of 40 students had the term and withdrawal effective date reported to NSLDS inaccurately; 4. Eight of 12 monthly rosters returned by NSLDS due to errors were not corrected and resubmitted within the 10-day period; and 5. Two out of 40 students tested did not have their enrollment status in the NSLDS database timely or accurately updated from `W? to `G? once the correct effective date was determined. Questioned costs: None Repeat finding?: No Recommendation: Management should review the controls and procedures in place to verify that accurate, timely, and complete data is being submitted to NSLDS. This should include separation of preparation, review, and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2020-001 Finding: The School submits batch uploads to the National Student Loan Data System (NSLDS) on a monthly basis, and makes adjustments in between submissions directly via the NSLDS website. While testing Enrollment Reporting, it was noted: 1. A student?s withdrawal was reported to the NSLDS enrollment database after the required 60-day enrollment certification requirement; 2. Some students reported effective enrollment date was reported inaccurately; 3. A student?s program type and begin date for the period from which they withdrew was reported inaccurately; 4. Roster error files received from NSLDS had errors that were not corrected timely; and 5. Some students initially reported as withdrawn were not timely or accurately reported as graduated after graduated status was confirmed. Corrective Actions Taken or Planned: MHSL is taking the below steps. ? The Academic Affairs Office increased staff and is implementing better tracking of students to prevent the need to backdating of withdrawals. ? The Financial Aid Office and Dean of Students have developed a job aid to determine LDA in compliance with NSLDS standards to be used in student withdrawal process. ? The NSC graduate reporting schedule will be increased and the NSC enrollment reports will become the primary source for NSLDS reports. Contact Person: Lynn LeMoine ? Dean of Students; Colleen Clish ? Registrar; and Nick Anderson ? Financial Aid Director. Anticipated Completion Date: 6/14/2021
While testing Return of Title IV Funds and Withdrawals, it was noted that a student was determined to be withdrawn, due to being deceased, but did not have a determination of earned Title IV aid performed by the School, and therefore unearned aid was not timely returned. Criteria: Per 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an School during a payment period or period of enrollment in which the recipient began attendance, the School must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Per 34 CRF 668.22(c)(1)(iv) and FSA HB C-4, the School must also make a determination of the withdrawal date, which can be no later than the date of a student?s death, if the School is not required to take attendance, or the last date of attendance, if the School is required to take attendance. Per 34 CFR 668.22(j), a school must always return any unearned Title IV funds it is responsible for returning within 45 days of the date the school determined the student withdrew. Cause: During the Fall 2019 semester, a student passed away before the end of the term, but the School determined the student completed enough course work to earn a passing grade in the term. The desire was to issue a posthumous degree. Since the School considered the student to have a passing grade for the term there was a concern completing a Return of Title IV funds refund calculation would conflict with ability to award the posthumous degree; therefore, the calculation was not completed. Effect: The amount of Federal Direct Loan Funds earned was not determined, and therefore the unearned amount was not properly returned to the ED within 45 days of the School determining that the student withdrew. Prevalence: One of 14 students tested, out of a population of 71 students, did not have funds properly returned within the 45-day period. Questioned costs: Known questioned costs are $4,130 of unearned Federal Direct Loan aid to be returned by the School. Unearned Federal Direct Loan aid to be returned by the student is considered $0 per 34 CFR 685.212(a). Repeat finding?: No Recommendation: Return of Title IV Funds calculations are being performed when required, and funds are being properly returned within the 45-day required time frame. View of responsible officials of the auditee: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2020-002 Return of Title IV Funds U.S. Department of Education Program Student Financial Assistance Programs Cluster Federal Direct Student Loans (CFDA 84.268) Federal Award Year: 2019?2020 Condition: While testing Return of Title IV Funds and Withdrawals, it was noted that a student was determined to be withdrawn, due to being deceased, but did not have a determination of earned Title IV aid performed by the School, and therefore unearned aid was not timely returned. Criteria: Per 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an School during a payment period or period of enrollment in which the recipient began attendance, the School must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Per 34 CRF 668.22(c)(1)(iv) and FSA HB C-4, the School must also make a determination of the withdrawal date, which can be no later than the date of a student?s death, if the School is not required to take attendance, or the last date of attendance, if the School is required to take attendance. Per 34 CFR 668.22(j), a school must always return any unearned Title IV funds it is responsible for returning within 45 days of the date the school determined the student withdrew. Cause: During the Fall 2019 semester, a student passed away before the end of the term, but the School determined the student completed enough course work to earn a passing grade in the term. The desire was to issue a posthumous degree. Since the School considered the student to have a passing grade for the term there was a concern completing a Return of Title IV funds refund calculation would conflict with ability to award the posthumous degree; therefore, the calculation was not completed. Effect: The amount of Federal Direct Loan Funds earned was not determined, and therefore the unearned amount was not properly returned to the ED within 45 days of the School determining that the student withdrew. Prevalence: One of 14 students tested, out of a population of 71 students, did not have funds properly returned within the 45-day period. Questioned costs: Known questioned costs are $4,130 of unearned Federal Direct Loan aid to be returned by the School. Unearned Federal Direct Loan aid to be returned by the student is considered $0 per 34 CFR 685.212(a). Repeat finding?: No Recommendation: Return of Title IV Funds calculations are being performed when required, and funds are being properly returned within the 45-day required time frame. View of responsible officials of the auditee: Management agrees with this finding.
Identifying Number: 2020-002 Finding: While testing Return of Title IV Funds and Withdrawals, it was noted that a student determined to be withdrawn, due to being deceased, did not have a determination of earned Title IV aid performed by the School, and therefore unearned aid was not timely returned. Corrective Actions Taken or Planned: Should a future unfortunate situation arise in which a current student is deceased during the course of instruction, the student will be withdrawn immediately using the last date of attendance, if known, or the date of death, whichever is earlier. The Dean of Students will determine the last date of attendance based on the totality of the information available at the time of the student?s death. Posthumous degrees will be determined and awarded separately from the process which governs the Return of Title IV Funds and Withdrawals. Contact Person: Lynne LeMoine Dean of Students Anticipated Completion Date: 6/14/2021
FAC accepted this audit on December 17, 2018 — management decision was due June 17, 2019.
GSA_MIGRATION
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GSA_MIGRATION
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