EIN: 431007642
UEI: C173L8LFLCE4
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 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 24, 2026 (27 days from today).
What is a management decision? →Students were not appropriately awarded subsidized loans up to their eligible annual limit prior to considering unsubsidized loans. Criteria: 34 CFR 685.200(a)(1)(iii); HEA: Sec. 484 Questioned Costs: $6,250 Context: Out of 31 students tested, 6 students were under awarded $6,250 total in subsidized direct loans since they were awarded and disbursed below their maximum eligibility for the year. The amounts under awarded ranged from $375 - $2,062 per student. Cause: The University improperly reduced student's overall federal direct loans instead of just their unsubsidized direct loan. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University ensure that students are awarded their maximum subsidized loan eligibility prior to considering unsubsidized loans. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Considering Subsidized Loans First Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loan Program Federal Award Identification #: P268K253147 Condition: Students were not appropriately awarded subsidized loans up to their eligible annual limit prior to considering unsubsidized loans. Criteria: 34 CFR 685.200(a)(1)(iii); HEA: Sec. 484 Questioned Costs: $6,250 Context: Out of 31 students tested, 6 students were under awarded $6,250 total in subsidized direct loans since they were awarded and disbursed below their maximum eligibility for the year. The amounts under awarded ranged from $375 - $2,062 per student. Cause: The University improperly reduced student's overall federal direct loans instead of just their unsubsidized direct loan. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University ensure that students are awarded their maximum subsidized loan eligibility prior to considering unsubsidized loans. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2025-001 Considering Subsidized Loans First Planned Corrective Action: The financial aid office concurs with this finding. We have received guidance from our annual audit partners and will install updated processes to ensure that consideration of subsidized loans is prioritized during the awarding process. Person Responsible for Corrective Action Plan: Brice Baumgardner, Vice President of Enrollment Management Anticipated Date of Completion: 4/1/2026
FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.
The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2022-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2022-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University is making progress to fully comply with GLBA regulations. The University is in process to improve safeguards, monitoring, training, vendor management, and updating the information security program. The Director of Computer Services presented a written report to the executive board in January 2024 and this will now be provided and presented annually. The University has been transitioning into a more stable financial situation and intends to continue to provide needed resources in security areas. Administrators are working to add budget lines specific and unique to improving campus cybersecurity issues, demonstrating a commitment to continual improvement in these areas. Person Responsible for Corrective Action Plan: Dr. Michelle Todd, Director of Computer Services, Computer Sciences, Chair, Professor of Information Sciences Anticipated Date of Completion: Spring, 2025
2022-002
The University did not report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 66 students tested for proper NSLDS enrollment status, 7 students had not been properly reported as graduated to NSLDS. Cause: The University submitted accurate information to their third-party administrator however the University had not performed periodic checks to ensure that student information was uploaded to NSLDS accurately. Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend the University complete spot checks of NSLDS enrollment statuses throughout the year including a graduation spot check after each academic term. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 66 students tested for proper NSLDS enrollment status, 7 students had not been properly reported as graduated to NSLDS. Cause: The University submitted accurate information to their third-party administrator however the University had not performed periodic checks to ensure that student information was uploaded to NSLDS accurately. Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend the University complete spot checks of NSLDS enrollment statuses throughout the year including a graduation spot check after each academic term. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. Student information is uploaded to the NSLDS monthly, so this should provide another layer of assurance each time information is submitted. An internal deadline and standing meeting will be established to ensure consistent compliance. Person Responsible for Corrective Action Plan: Joseph D. Garner III, Registrar Anticipated Date of Completion: The new process will begin April, 2024.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not fully documented its security risk assessment and safeguards. Cause: The University experienced turnover of the IT personnel responsible over GLBA compliance as well as the impact on IT operations by COVID-19. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not fully documented its security risk assessment and safeguards. Cause: The University experienced turnover of the IT personnel responsible over GLBA compliance as well as the impact on IT operations by COVID-19. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach -Bliley Act (GLBA) Compliance Planned Corrective Action: In regards to the Gramm-Leach-Bliley Act (GBLA), we concur that Hannibal- LaGrange University (HLGU) has not adequately addressed the requirements of the GBLA. In an effort to rectify this issue, the director of Computer Services, Dr. Michelle Todd, is in contact with the security team of the Missouri Research and Education Network (MORENet) and has begun to work through a security assessment, which provides a roadmap for making current and continual improvements in regards to the security of the network. MOREN et is a membership consortium that operates as a department within the University of Missouri System, assisting members with network and security support. This process with MORENet will provide HLGU with guidance to develop a program that would protect the exposure of student information security risks. Person Responsible for Corrective Action Plan: Dr. Michelle Todd, Director of Computer Services Anticipated Date of Completion: Fall 2023
FAC accepted this audit on March 29, 2022 — management decision was due September 29, 2022.
During the course of our audit, we sampled 60 students that received Title IV funds and sampled 58% of students who withdrew during the fiscal year for compliance with requirements regarding status updates. We found that one student?s status was not updated correctly in the U.S. Department of Education?s NSLDS system. Cause of Condition: The University is required to report status changes in its next scheduled enrollment submission to NSLDS. Due to the timing of when the student withdrew and the end of the term, the enrollment submission file reported the effective date of the status change as September 20, 2020, the last day of the term, rather than the student?s actual withdrawal date, August 26, 2020. Presumably, the wrong date was reported because the student was no longer enrolled at the University by the time the next enrollment file was submitted. Effect: The effective date of the status change should have been the withdrawal date which was August 26, 2020. The change in status is used to determine the grace period for Direct Loans, therefore, using an incorrect date would cause the grace period to begin on an incorrect date. Recommendation: We recommend that the University employ stronger oversight in this area by implementing procedures to ensure student statuses are updated correctly and timely. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely. Response: We agree with this finding that the improper withdrawal date was applied to the student in question. Moving forward to prevent future errors of this type, the Registrar's has standardized the procedure by which Student Withdraw documentation is processes and has increased communication with the Financial Aid Office when there are questions concerning withdraw dates. The Registrar's Office has also begun to date stamp all Student Withdrawal forms as they are received to ensure that they are processed in a timely manner and that the proper withdraw dates are recorded. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-002 ? NSLDS Enrollment Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 682.610(c)(1)-(c)(2), Hannibal-LaGrange University is required to promptly notify the U.S. Department of Education of changes in student status in a timely and accurate manner to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds and sampled 58% of students who withdrew during the fiscal year for compliance with requirements regarding status updates. We found that one student?s status was not updated correctly in the U.S. Department of Education?s NSLDS system. Cause of Condition: The University is required to report status changes in its next scheduled enrollment submission to NSLDS. Due to the timing of when the student withdrew and the end of the term, the enrollment submission file reported the effective date of the status change as September 20, 2020, the last day of the term, rather than the student?s actual withdrawal date, August 26, 2020. Presumably, the wrong date was reported because the student was no longer enrolled at the University by the time the next enrollment file was submitted. Effect: The effective date of the status change should have been the withdrawal date which was August 26, 2020. The change in status is used to determine the grace period for Direct Loans, therefore, using an incorrect date would cause the grace period to begin on an incorrect date. Recommendation: We recommend that the University employ stronger oversight in this area by implementing procedures to ensure student statuses are updated correctly and timely. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely. Response: We agree with this finding that the improper withdrawal date was applied to the student in question. Moving forward to prevent future errors of this type, the Registrar's has standardized the procedure by which Student Withdraw documentation is processes and has increased communication with the Financial Aid Office when there are questions concerning withdraw dates. The Registrar's Office has also begun to date stamp all Student Withdrawal forms as they are received to ensure that they are processed in a timely manner and that the proper withdraw dates are recorded. See Corrective Action Plan.
Finding 2021-002 NSLDS Enrollment Reporting (Not a Repeat Finding) Response: We agree with this finding that the improper withdrawal date was applied to the student in question. Moving forward to prevent future errors of this type, the Registrar's has standardized the procedure by which Student Withdraw documentation is processes and has increased communication with the Financial Aid Office when there are questions concerning withdraw dates. The Registrar's Office has also begun to date stamp all Student Withdrawal forms as they are received to ensure that they are processed in a timely manner and that the proper withdraw dates are recorded. These new processes began in September 2021.
During the course of our audit, we sampled 60 students that received Title IV funds and sampled 58% of students who withdrew during the fiscal year for compliance with requirements regarding exit counseling. We found that two students were not properly notified in a timely manner of the requirement to complete exit counseling. Cause of Condition: Exit counseling notification was not sent due to an oversight. Proper review was not provided to ensure every step of the withdrawal process was performed correctly and completely by the Financial Aid and Registrar?s office. Effect: Students that are not provided with exit counseling materials may not be fully aware of their repayment responsibilities, which could result in additional defaults on the loan program. Recommendation: We recommend that the University employ stronger oversight in this area by implementing procedures to ensure students are notified to perform exit counseling in a timely manner. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely. Response: We concur with this finding that exit counseling materials were not sent in a timely manner. In the audited year the Office of the Registrar was down to one staff member for a significant amount of time and this caused the oversight. When the new Registrar arrived to campus, he and his team installed a new process wherein a report is generated and sent to the Financial Aid Office. This report is generated in such a way that will ensure accuracy of timely notification of exit counseling materials to students. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-003 ? Exit Counseling (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 682.604(g), if a student borrower withdraws from school, the University must notify the student of the exit counseling requirements within 30 days after learning that the student has withdrawn. Condition: During the course of our audit, we sampled 60 students that received Title IV funds and sampled 58% of students who withdrew during the fiscal year for compliance with requirements regarding exit counseling. We found that two students were not properly notified in a timely manner of the requirement to complete exit counseling. Cause of Condition: Exit counseling notification was not sent due to an oversight. Proper review was not provided to ensure every step of the withdrawal process was performed correctly and completely by the Financial Aid and Registrar?s office. Effect: Students that are not provided with exit counseling materials may not be fully aware of their repayment responsibilities, which could result in additional defaults on the loan program. Recommendation: We recommend that the University employ stronger oversight in this area by implementing procedures to ensure students are notified to perform exit counseling in a timely manner. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely. Response: We concur with this finding that exit counseling materials were not sent in a timely manner. In the audited year the Office of the Registrar was down to one staff member for a significant amount of time and this caused the oversight. When the new Registrar arrived to campus, he and his team installed a new process wherein a report is generated and sent to the Financial Aid Office. This report is generated in such a way that will ensure accuracy of timely notification of exit counseling materials to students. See Corrective Action Plan.
Finding 2021-003 Exit Counseling (Not a Repeat Finding) Response: We concur with this finding that exit counseling materials were not sent in a timely manner. In the audited year the Office of the Registrar was down to one staff member for a significant amount of time and this caused the oversight. When the new Registrar arrived to campus, he and his team installed a new process wherein a report is generated and sent to the Financial Aid Office. This report was implemented in September of 2021 and has been delivered monthly since. This report is generated in such a way that will ensure accuracy of timely notification of exit counseling materials to students.
During the course of our audit, we reviewed the required reports for the Institutional and Student Aid Portions of HEERF for accuracy and timely public posting. One Student Aid Portion report was not posted within the required timeframe. The University is required to publicly post to their website the Student Aid Portion quarterly reports no later than 30 days after the receipt of the allocation, then update that information every 45 days thereafter by posting a new report. Effective August 31, 2020, the frequency of reporting was decreased to no later than 10 days after the calendar quarter. The August 24, 2020 report was posted 54 days after the previous July 1, 2020 report, exceeding the 45 day requirement. In addition, we were not able to reconcile the items reported on the Institutional Portion quarterly public reporting with underlying supporting documentation. Cause of Condition: The late posting of the next Student Aid Portion report was an oversight. Due to a key staff?s leave of absence, documentation was not able to be produced to fully support the items reported on the quarterly reporting. Effect: Institutions that do not meet the reporting requirements may be subject to enforcement actions, up to and including being determined to be ineligible for certain other HEERF program funding. Recommendation: We recommend that the University implement a process to ensure all required reporting is being performed accurately and timely and put oversight procedures into practice over this process. Response: We concur with this finding that the late posting of the Student Aid Portion Report was an oversight. As a corrective action, beginning July 1, 2021, current personnel have been working as a team to track reporting due dates to ensure reports are filed in a timely manner. We further concur that the departure of key personnel who were responsible for the HEERF Fund reporting created difficulty in the production of supporting documentation for a small portion of the expended funds. Effective July 1, 2021, a HEERF Team was developed to track and document the spending of HEERF Funds. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-004 ? HEERF Funds Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Education Stabilization Fund: Higher Educations Emergency Relief (HEERF) Student Aid Portion (Assistance Listing No. 84.425E); and HEERF Institutional Portion (Assistance Listing No. 84.425F) Requirement: Reporting Criteria: Under CARES Act Sections 18004(a)(1) Institutional Portion and 18004(a)(2), Hannibal-LaGrange University is required to prepare and publicly post on the institution?s website completed quarterly reports for the Institutional and Student Aid Portions of HEERF funds in a timely and accurate manner to ensure compliance with reporting. Condition: During the course of our audit, we reviewed the required reports for the Institutional and Student Aid Portions of HEERF for accuracy and timely public posting. One Student Aid Portion report was not posted within the required timeframe. The University is required to publicly post to their website the Student Aid Portion quarterly reports no later than 30 days after the receipt of the allocation, then update that information every 45 days thereafter by posting a new report. Effective August 31, 2020, the frequency of reporting was decreased to no later than 10 days after the calendar quarter. The August 24, 2020 report was posted 54 days after the previous July 1, 2020 report, exceeding the 45 day requirement. In addition, we were not able to reconcile the items reported on the Institutional Portion quarterly public reporting with underlying supporting documentation. Cause of Condition: The late posting of the next Student Aid Portion report was an oversight. Due to a key staff?s leave of absence, documentation was not able to be produced to fully support the items reported on the quarterly reporting. Effect: Institutions that do not meet the reporting requirements may be subject to enforcement actions, up to and including being determined to be ineligible for certain other HEERF program funding. Recommendation: We recommend that the University implement a process to ensure all required reporting is being performed accurately and timely and put oversight procedures into practice over this process. Response: We concur with this finding that the late posting of the Student Aid Portion Report was an oversight. As a corrective action, beginning July 1, 2021, current personnel have been working as a team to track reporting due dates to ensure reports are filed in a timely manner. We further concur that the departure of key personnel who were responsible for the HEERF Fund reporting created difficulty in the production of supporting documentation for a small portion of the expended funds. Effective July 1, 2021, a HEERF Team was developed to track and document the spending of HEERF Funds. See Corrective Action Plan.
Finding 2021-004 - HEERF Funds Reporting (Not a Repeat Finding) We concur with this finding that the late posting of the Student Aid Portion Report was an oversight. As a corrective action, beginning July 1, 2021, current personnel have been working as a team to track reporting due dates to ensure reports are filed in a timely manner. We further concur that the departure of key personnel who were responsible for the HEERF Fund reporting created difficulty in the production of supporting documentation for a small portion of the expended funds. Effective July 1, 2021, a HEERF Team was developed to track and document the spending of HEERF Funds.
FAC accepted this audit on November 4, 2020 — management decision was due May 4, 2021.
During the course of our audit, we sampled 50% of the students who withdrew during the fiscal year for compliance with requirements regarding the return of Title IV funds. We found one instance in which the number of completed days used in the calculation for determining the percentage of Title IV funds the student had earned was incorrect. Per Chapter 2?The Steps in a Return of Title IV Aid Calculation on page 5-81 of the Federal Student Aid Handbook, there is an example given that states if a student officially withdraws while on a scheduled break, the withdrawal date is the last date of scheduled class attendance prior to the start of the scheduled break. Cause of Condition: Proper oversight was not provided for the calculation of the return of Title IV funds to ensure every step is performed correctly and funds are returned timely. The student withdrew from the University during a scheduled break and the University did not correctly enter the proper withdrawal date which, in turn, caused the number of completed days to be incorrect in the earned percentage calculation. Effect: By using the incorrect number of completed days, the University is not calculating the percentage of awards earned correctly. This may cause the University to return more or less funds than necessary. Also, the return of Title IV funds can affect the student?s outstanding Direct loan balance since returning an incorrect amount also results in an incorrect outstanding loan balance. Lastly, if timely return of Title IV funds is not made, the University is in violation of the return requirements. Recommendation: We recommend that the University engage in training of return of Title IV funds and use financial aid resources available to ensure the accuracy of the calculation. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of the return process are being completed correctly and that term dates are correct. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2020-001 ? (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (CFDA No.?s 84.007, 84.033, 84.038, 84.063, 84.268) Criteria: Hannibal-LaGrange University is required to make return of Title IV funds in the proper amount and in a timely manner to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 50% of the students who withdrew during the fiscal year for compliance with requirements regarding the return of Title IV funds. We found one instance in which the number of completed days used in the calculation for determining the percentage of Title IV funds the student had earned was incorrect. Per Chapter 2?The Steps in a Return of Title IV Aid Calculation on page 5-81 of the Federal Student Aid Handbook, there is an example given that states if a student officially withdraws while on a scheduled break, the withdrawal date is the last date of scheduled class attendance prior to the start of the scheduled break. Cause of Condition: Proper oversight was not provided for the calculation of the return of Title IV funds to ensure every step is performed correctly and funds are returned timely. The student withdrew from the University during a scheduled break and the University did not correctly enter the proper withdrawal date which, in turn, caused the number of completed days to be incorrect in the earned percentage calculation. Effect: By using the incorrect number of completed days, the University is not calculating the percentage of awards earned correctly. This may cause the University to return more or less funds than necessary. Also, the return of Title IV funds can affect the student?s outstanding Direct loan balance since returning an incorrect amount also results in an incorrect outstanding loan balance. Lastly, if timely return of Title IV funds is not made, the University is in violation of the return requirements. Recommendation: We recommend that the University engage in training of return of Title IV funds and use financial aid resources available to ensure the accuracy of the calculation. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of the return process are being completed correctly and that term dates are correct. Response: See Corrective Action Plan.
Finding 2020-001 Corrective Action Plan At the conclusion of our annual audit, we were notified of an error in processing. During the audit, 50% of our R2T4 files were selected for review. After the review was completed, it was determined that one of the files contained an error in processing. The aid office has recalculated the error in processing which totaled 1.7% difference from the original calculation in the Federal Pell Grant program. The 36 dollars of Federal Pell Grant funds has been retuned. The aid office also reviewed the other 50% of our R2T4 files that were not selected for the audit review and found them to be without error. The student who withdrew submitted their official documentation to the University during a scheduled break. The aid office received the withdrawal form and processed the form through our student information system, Colleague. In Colleague, we are able to identify breaks in the period and enter them into the system. We do this to ensure accurate tracking and calculation of time enrolled in each period for the R2T4 process. When we processed this student, the two break days prior to the withdraw date were counted in the calculation. HLGU was instructed in software implementation, that having the break days,included in the award period set up in Colleague would remove those days from the calculation 'to ensure an accurate count and calculation. The aid office has reached out to our Computer Services team and is working with them to receive clarification from Colleague for a resolution. For the 2021-2022 year, we have spent additional financial aid resources on training in all areas of financial aid and, specifically, in R2T4. We will be participating in upcoming training on R2T4 through the National Association of Financial Aid Administrators. This training will be able to be stored for future reference and serve as a training tool and resource going forward. We have also utilized resources to be a part of regular training opportunities throughout the year that will cover additional aid topics. We will be attending our virtual state conference to receive additional training on R2T4 in the next several weeks. After additional steps were added last year to the R2T4 process, we have also incorporated an additional layer of accuracy through a manual process of R2T4 processing for the upcoming year, in order to help provide increased accuracy of processing. As part of the manual process, we have printed physical copies of the calendar to help with counting the days attended. This will help ensure that the electronic process is working appropriately and to serve as an additional review step in the process.
2019-001
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
During the course of our audit, we obtained as list of all students who withdrew during the fiscal year. We tested each student that required a return of Title IV funds for compliance with requirements regarding the return of Title IV funds. We found one instance in which the number of completed days used in the calculation for determining the Title IV funds earned was incorrect. We also noted that one other student?s return of Title IV funds was not performed timely. The FDL portion was returned on June 7, 2019 and the SEOG portion was returned on August 5, 2019. However, the required return date is 45 days after the withdrawal date of April 24, 2019. Cause of Condition: Proper oversight was not provided for the calculation of the return of Title IV funds to ensure every step is performed correctly and funds are returned timely. The incorrect date was used as the date of withdrawal which, in turn, caused the number of completed days to be incorrect in the earned percentage calculation. The timeliness issue was due to a delay in calculating the required return amount to ensure that the return amount was correct and, subsequently, caused the return to be made later than required. Effect: By using the incorrect number of completed days, the University is not calculating the percentage of awards earned correctly. This may cause the University to return more or less funds than necessary. Also, the return of Title IV funds can affect the student?s outstanding Direct loan balance since returning an incorrect amount also results in an incorrect outstanding loan balance. Also, if timely returns of Title IV funds are not made, the University is in violation of the return requirements. Recommendation: We recommend that the University employ a review procedure including communication with other offices to ensure all steps of the return process are being completed correctly and that term dates are correct. Procedures also need to be put in place to ensure the funds to be returned are done in a correct, timely manner. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-001 ? (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (CFDA No.?s 84.007, 84.033, 84.038, 84.063, 84.268) Criteria: Hannibal-LaGrange University is required to make return of Title IV funds in the proper amount and in a timely manner to ensure compliance with special tests and provisions. Condition: During the course of our audit, we obtained as list of all students who withdrew during the fiscal year. We tested each student that required a return of Title IV funds for compliance with requirements regarding the return of Title IV funds. We found one instance in which the number of completed days used in the calculation for determining the Title IV funds earned was incorrect. We also noted that one other student?s return of Title IV funds was not performed timely. The FDL portion was returned on June 7, 2019 and the SEOG portion was returned on August 5, 2019. However, the required return date is 45 days after the withdrawal date of April 24, 2019. Cause of Condition: Proper oversight was not provided for the calculation of the return of Title IV funds to ensure every step is performed correctly and funds are returned timely. The incorrect date was used as the date of withdrawal which, in turn, caused the number of completed days to be incorrect in the earned percentage calculation. The timeliness issue was due to a delay in calculating the required return amount to ensure that the return amount was correct and, subsequently, caused the return to be made later than required. Effect: By using the incorrect number of completed days, the University is not calculating the percentage of awards earned correctly. This may cause the University to return more or less funds than necessary. Also, the return of Title IV funds can affect the student?s outstanding Direct loan balance since returning an incorrect amount also results in an incorrect outstanding loan balance. Also, if timely returns of Title IV funds are not made, the University is in violation of the return requirements. Recommendation: We recommend that the University employ a review procedure including communication with other offices to ensure all steps of the return process are being completed correctly and that term dates are correct. Procedures also need to be put in place to ensure the funds to be returned are done in a correct, timely manner. Response: See Corrective Action Plan.
While we acknowledge the referenced finding in which the number of completed days used in the calculation was incorrect, we do not concur that this was repeat finding. This error was specifically due to a data entry error into the electronic return of fund calculation inside of our financial aid management system. Specifically, when the return was processed, the last date of attendance was picked up as 2/5/19, when in fact, it was 2/4/19. When the return was reviewed by another staff member in the office, the date on the form, below the last date of attendance was 2/5/19 and therefore, that staff member validated the incorrect date. In our previous audit we received a finding of incorrect dates that were used when a scheduled break was inadvertently excluded in the calculation for students. This error was corrected with the implementation of our newest software. A review process was put in place last year to catch date range calculations for closed break days. Again, while we acknowledge that both years had a date challenge, we do believe that a missed keystroke is different than not including break days-in the calculation. From the second week of December through the second week of June the financial aid office was not fully staffed as we had a maternity leave, resignation and reorganization of the office during this time. I recognize the significant challenges that this placed on myself and our other team member. However, in response to this finding, the financial aid office, in consultation with the Vice President of Business and Finance, has developed several new processes to strengthen our R2T4 processing. Our first initiative is that we have reviewed, discussed and redesigned the return process in the financial aid office. We have instituted a three-step review. They will be stored electronically at the conclusion of the process. This additional review will allow us to review and track all needed items for a successful and timely return. In an effort to streamline the process we moved many items to an electronic process. We have noted in our discussions that this has potentially had a negative impact on our processing as it did not consolidate items needed for a return. We are returning to keeping a hard copy file of our work to make sure all of our documents are centrally located. They will be stored electronically at the conclusion of the process. Our second initiative is a Return of Title IV Checklist has been created. This form lists each item needed to process a return. It will aid the three financial aid team members in each step of the review. Our third initiative is the implementation of a monthly review of every return that has been processes in the last thirty days. This will serve as another level of review for accuracy and timeliness of processing. We feel these three initiatives will safeguard against these types of R2T4 errors in the future.
2018-001
During the course of our audit, we sampled 27% of the students who withdrew during the fiscal year for compliance with requirements regarding status updates and exit counseling. We found that one student?s status was not updated correctly in the U.S. Department of Education?s NSLDS system. We also found that three students were not properly notified in a timely manner of the requirement to complete exit counseling. Cause of Condition: The University is required to report status changes in its next scheduled enrollment submission to NSLDS. Due to the timing of when the student withdrew and the end of the term, the enrollment submission file reported the effective date of the status change as March 24, 2019, the last day of the term because the student was no longer enrolled at the University by the time the next enrollment file was submitted. Exit counseling notification was not sent due to an oversight. Proper review was not provided to ensure every step of the withdrawal process is performed correctly and completely by the Financial Aid and Registrar?s office. Effect: The effective date of the status change should have been the date of determination which was January 30, 2019. The changes in status is used to determine the grace period for Direct Loans, therefore, using an incorrect date would cause the grace period to begin later than it actually should begin. Exit counseling provides students with essential information to prepare the students for loan repayment. Recommendation: We recommend that the University employ stronger oversight in this area by implementing procedures to ensure student statuses are updated correctly and timely. Review procedures also need to be put in place to ensure students are notified to perform exit counseling in a timely manner. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-002 ? (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (CFDA No.?s 84.007, 84.033, 84.038, 84.063, 84.268) Criteria: Hannibal-LaGrange University is required to promptly notify the U.S. Department of Education of changes in student status in a timely and accurate manner to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 27% of the students who withdrew during the fiscal year for compliance with requirements regarding status updates and exit counseling. We found that one student?s status was not updated correctly in the U.S. Department of Education?s NSLDS system. We also found that three students were not properly notified in a timely manner of the requirement to complete exit counseling. Cause of Condition: The University is required to report status changes in its next scheduled enrollment submission to NSLDS. Due to the timing of when the student withdrew and the end of the term, the enrollment submission file reported the effective date of the status change as March 24, 2019, the last day of the term because the student was no longer enrolled at the University by the time the next enrollment file was submitted. Exit counseling notification was not sent due to an oversight. Proper review was not provided to ensure every step of the withdrawal process is performed correctly and completely by the Financial Aid and Registrar?s office. Effect: The effective date of the status change should have been the date of determination which was January 30, 2019. The changes in status is used to determine the grace period for Direct Loans, therefore, using an incorrect date would cause the grace period to begin later than it actually should begin. Exit counseling provides students with essential information to prepare the students for loan repayment. Recommendation: We recommend that the University employ stronger oversight in this area by implementing procedures to ensure student statuses are updated correctly and timely. Review procedures also need to be put in place to ensure students are notified to perform exit counseling in a timely manner. Response: See Corrective Action Plan.
The financial aid office acknowledges the oversight in exit counseling notifications. We have redesigned our process for student withdraws. As a part of this process we have added a third reviewer to assist with the review of each withdrawal. This additional reviewer will ensure that an accurate and timely notification process has been completed by the Financial Aid and Registrar's office. We acknowledge and concur with this finding regarding accurate reporting of this one student's withdraw date. Due to the nature of the degree completion program, the institution has reported student enrollment statuses each month because in the past there have been multiple terms running simultaneously. We have previously understood that reporting monthly is acceptable for meeting our enrollment reporting requirement. The structure of the degree completion program has recently changed and we are phasing out the last semester that has two terms running simultaneously. After review of the scheduled timeline for reporting, I will update the reporting dates to dates similar to the traditional and graduate term schedules. These two programs have specific requirements for reporting enrollment 14-21 number of days after a term begins, within 5 days before a term ends, and at least every 45 days between those dates. Reporting within 5 days of a term ends will ensure that it is past the date to withdraw from courses and capture an accurate enrollment status change date.
During the course of our audit, we sampled 60 students who received federal awards during the fiscal year for compliance with requirements regarding eligibility. We found that one student was incorrectly awarded Federal Supplemental Educational Opportunity Grant (FSEOG). Cause of Condition: The University implemented a new software system and the rule defining eligibility regarding FSEOG was incorrectly written. The error was corrected to award FSEOG to students that had financial need, met general eligibility requirements, enrolled as an undergraduate student, and that had not previously earned a bachelor?s or first professional degree. However, the student was awarded FSEOG before this correction was made. Effect: Although the rule had been corrected, the University failed to review FSEOG already awarded to students before the error was corrected and had erroneously awarded FSEOG to a student who had previously earned her bachelor?s degree and was pursuing a second bachelor?s degree. Therefore, the student was not eligible to receive FSEOG. Recommendation: Although this software issue was corrected, we recommend that the University ensure its policies include a procedure to retroactively review awards when a software issue is detected. This will assist in correcting any previously erroneous awards. Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-003 ? (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (CFDA No.?s 84.007, 84.033, 84.038, 84.063, 84.268) Criteria: Hannibal-LaGrange University is required to ensure only eligible students received federal awards to ensure compliance with eligibility and special tests and provisions. Condition: During the course of our audit, we sampled 60 students who received federal awards during the fiscal year for compliance with requirements regarding eligibility. We found that one student was incorrectly awarded Federal Supplemental Educational Opportunity Grant (FSEOG). Cause of Condition: The University implemented a new software system and the rule defining eligibility regarding FSEOG was incorrectly written. The error was corrected to award FSEOG to students that had financial need, met general eligibility requirements, enrolled as an undergraduate student, and that had not previously earned a bachelor?s or first professional degree. However, the student was awarded FSEOG before this correction was made. Effect: Although the rule had been corrected, the University failed to review FSEOG already awarded to students before the error was corrected and had erroneously awarded FSEOG to a student who had previously earned her bachelor?s degree and was pursuing a second bachelor?s degree. Therefore, the student was not eligible to receive FSEOG. Recommendation: Although this software issue was corrected, we recommend that the University ensure its policies include a procedure to retroactively review awards when a software issue is detected. This will assist in correcting any previously erroneous awards. Response: See Corrective Action Plan.
We concur with this finding of a student being incorrectly awarded a Federal Supplemental Educational opportunity Grant (FSEOG), During the implementation of our new software system we contracted with our software provider for setup of our awards. The FSEOG rule was incorrectly written during the initial phase of implementation of the financial aid module. Awards were set up and put into place for us for the awarding year. A financial aid team member was reviewing the Federal Student Aid handbook and was reading about FSEOG and noted that our award was missing a specific rule. We contacted our Computer Services department and reviewed our award. It was determined that in fact we were missing a rule. We corrected the rule at that time. We have developed a policy and process to review awards that are found to contain an error, This process will assist us in correcting awards that have been made previous to the identification of the of the award and allow us to proceed with accurate awards.
FAC accepted this audit on October 23, 2018 — management decision was due April 23, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on January 15, 2018 — management decision was due July 15, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
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