Midland UniversityHigher Education

Finding 2025-001: Significant Deficiency – Return of Title IV funds Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K251780 Federal Award Year: June 30, 2025 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: Of the 16 students tested in the sample, one student did not have an R2T4 completed during Summer 2024. Subsequent to the auditor identifying this exception in July 2025 the University completed the calculation and returned the required funds. The auditor reviewed the calculation and student's account statement confirming that corrective action was taken. The sample was not a statistically valid sample. Cause: The University's controls surrounding return of Title IV calculations did not appropriately ensure the return was completed timely. Effect: The unearned funds were not returned to the U.S. Department of Education. Questioned Costs: A total of $3,805 in Federal Direct Loans assistance listing number 84.268. Recommendation: The University should revise its procedures and controls to ensure that the return of Title IV calculations are completed timely and accurately for all students who withdraw. Management's Response: The University agrees with the finding. The University believes this was an isolated incident related to the turnover of the Financial Aid Director position. Beginning in Summer 2025, the new Financial Aid Director and Registrar have been meeting bi-weekly to discuss all changes of enrollment including withdrawals. The process ensures that all students are reviewed and all R2T4s are completed on all students who withdraw from Midland University and have Title IV funding.

Finding 2025-002: Significant Deficiency – NSLDS Enrollment Reporting Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K251780 Federal Award Year: June 30, 2025 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of the 25 students tested, two students had incorrect or late information reported. One student’s withdrawn date reported in spring 2025 was incorrect and did not agree to the University’s documentation to support the date of determination. A second student’s status’ certification date was reported 71 days after their date of determination. The sample was not a statistically valid sample. Cause: The University's controls surrounding the reporting of students’ statuses and status effective dates to the National Student Loan Data System (NSLDS) did not appropriately ensure the information was submitted accurately or timely. Effect: Information reported to NSLDS was either incorrect or not updated timely. Questioned Costs: N/A Recommendation: The University should revise its procedures and controls to ensure NSLDS enrollment reporting is completed accurately and timely for all students’ status and status effective dates. Management's Response: The University agrees with the finding. The University believes this was an isolated incident related to the turnover of the Financial Aid Director position in coordination with the registrar’s office that performs the NSLDS reporting. Beginning in Summer 2025, the new Financial Aid Director and Registrar have been meeting bi-weekly to discuss all aspects of enrollment reporting. This will ensure that both offices are aware of reporting requirements and timelines.

Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K241780 Federal Award Year: May 31, 2024 Criteria: Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Additionally, when Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Condition/Context: For the 25 disbursements tested, notifications provided to students did not include the amount and type of Title IV funds they should expect to receive or the student's right, or parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Cause: The University's controls surrounding notification of Title IV disbursements did not appropriately ensure the communications sent to students and parents contained all of the required information. Effect: Students were not properly notified of the amount, type and cancellability of the Title IV funds they received. Questioned Costs: None. Recommendation: The University should revise its procedures to ensure that notifications of Title IV fund disbursements contain all of the information required by CFR 668.165. Management's Response: The University agrees with the finding. Processes surrounding Title IV funds disbursement notifications were reviewed and effective revisions were put in place in August 2024.

Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 4 of 25 students tested, the students’ Title IV credit balances on their accounts were held and applied to future charges without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization and applied to future charges. Questioned Costs: Total questioned costs were $18,947 of Federal Direct Student Loan funds ALN 84.268. Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024 term.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The following exceptions were noted in our testing:  Two students' graduate dates reported to NSLDS did not agree to the support provided from the University's system. The University subsequently corrected these students’ records in NSLDS and the auditor viewed the screen prints with the corrections.  One student was originally reported as half time to NSLDS and later changed full time and then back to half time. The full-time status was never reported NSLDS. The University subsequently corrected the student’s record in NSLDS and the auditor viewed the screen print with the corrections.  One student's change from full time to less than half time status was incorrectly not reported to NSLDS when they added a summer class during the summer of 2022. The University subsequently corrected the student’s record in NSLDS and the auditor viewed the screen prints with the corrections.  Two students with changes from full time to less than half time for the summer of 2023 were reported to the clearinghouse, but the notification in NSLDS does not show that the status was reflected within NSLDS program level or campus level reporting. The University provided screenshots showing that the enrollment history was updated in NSLDS for the two students.  One student with changes from full time to less than half time for the summer of 2023 were reported to the clearinghouse, but the notification in NSLDS does not show that the status was reflected within NSLDS campus level reporting. The status change does show up in the program level reporting. The University provided screenshots showing that the enrollment history was updated in NSLDS for the student. The sample was not a statistically valid sample. Cause: The University's controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS and a student was also omitted from reporting. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Management's Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.

Finding 2022-001: Significant Deficiency - Title IV Credit Balances Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 and 84.379 Federal Award Number: P268K221780 and P379T221780 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 4 of 25 students tested, the credit balance was not resolved in compliance with the regulations, the student?s Title IV credit balances on their accounts were held and applied to future charges without student or parent authorization. The first student?s Title IV credit balance was $759 of Direct Loan funds, the second student?s was $3,702 of Direct Loan funds, the third student?s was $390 of Direct Loan funds and the fourth student?s was $2,850 of Direct Loan funds and $943 of Teach Grant funds. The sample was not a statistically valid sample. Cause: The University?s controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization and applied to future charges. Questioned Costs: Total questioned costs were $7,701 of Direct Student Loan funds ALN 84.268 and $943 of Teach Grant funds ALN 84.379. Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management?s Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024 term.

Finding 2022-002: Significant Deficiency - NSLDS Enrollment Reporting Federal Program: Federal Direct Student Loans Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K221780 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: For 6 of 25 students tested, the status or status effective date was reported incorrectly or the student was not reported to NSLDS. ? Two students' withdrawn dates reported to NSLDS did not agree to the support provided from the University's system. Additionally, one of these student's enrollment status was reported incorrectly as full time not 3/4 time. The University subsequently corrected these students? records in NSLDS and the auditor viewed the screen prints with the corrections. ? One student's graduated date reported to NSLDS did not agree to the support provided from the University's system, however the University believes the date reported to NSLDS was correct and the system's date was incorrect. ? One student's full time status effective date was reported incorrectly as January 10, 2022 not August 30, 2021. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen print with the corrections. ? One student was incorrectly not reported to NSLDS when they attended and had Title IV loans during 2021-22. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen prints with the corrections. ? One student's status date reported to NSLDS for campus level of January 10, 2022 did not agree to the support provided by the University's system of April 4, 2022. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen print with the corrections. The sample was not a statistically valid sample. Cause: The University?s controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS and a student was also omitted from reporting. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Management?s Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.

Finding 2022-003: Significant Deficiency - Reporting - Higher Education Emergency Relief Fund Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.425 E and F Federal Award Number: P425E200098 and P425F200480 Federal Award Year: June 30, 2022 Repeat Finding: 2021-002 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: The quarterly and annual reporting contained some information that did not agree to support provided, and some of the quarterly reports were posted to the University?s website late. The University?s student portion quarterly reports June 30, 2021 and March 30, 2022 were selected for testing: ? Both reports included the number of students eligible for emergency student grants and the University was not able to provide support for as the counts were estimated. ? The June 30, 2021 report the amount of emergency grants disbursed to students and the number of students that received the grants both did not agree to the support provided. ? The June 30, 2021 report was posted to the University's website after the deadline of 10 days after calendar quarter end, it was posted October 27, 2021. ? The March 30, 2022 report, the amount of emergency grants disbursed to students and the number of students who received the grants were cumulative numbers and not just for the quarter as required. The University?s institutional portion quarterly report for June 30, 2021 selected for testing reported the total for lost revenue from academic sources and the total for other uses that did not agree to support provided. Additionally, the report was posted to the University's website after the deadline of 10 days after calendar quarter end, it was posted November 18, 2021. The 2021 annual report had some information that did not agree to the underlying support provided by the University. Specifically, the total for lost revenue and the total for other uses, and the required two new uses (direct outreach and monitoring and suppressing) were not reported although the support file provided did include costs for those items. Additionally, the number of students who received emergency grants did not agree to the support provided, and the institutional portion emergency grants to student accounts to cover outstanding amounts was reported incorrectly and should have been lost revenue for room and board refunds. The sample of reports tested was not a statistically valid sample. Cause: The University?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. Additionally, the University?s supporting files did not agree to the information reported. Effect: The University?s student portion reports contained some information that was cumulative and not quarterly as required and the institutional portion and annual report contained some information that was not accurate. Additionally, two of the quarterly reports were posted to the University?s website after the deadline. Questioned Costs: Not applicable Recommendation: The University should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Additionally, the University should ensure that it keeps supporting files that agree to all reporting. Management?s Response: The University is currently gathering data for the 2022 HEERF annual performance report to be completed between March 6 to March 24, 2023. During this time, corrections can and will be made to the 2021 annual performance report. Proper support will be maintained for both reports. There will be no reporting past calendar 2022 as all awarded HEERF funds have been expended.

Finding 2021-001: Significant Deficiency - Procurement Federal Program ? COVID-19 Education Stabilization Fund ? Institutional Portion Federal Agency ? U.S. Department of Education Pass-Through Entity ? Not Applicable CFDA Number ? 84.425F Federal Award Number ? P425F202752-20B Federal Award Year ? June 30, 2021 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The University?s policies and procedures over procurement generally conform to the requirements outlined by the Uniform Guidance with an exception over a suspension and debarment policy. The Uniform Guidance establishes methods of procurements to be utilized which relate to the acquisition of both goods and services. While the University has policies that outline procurement practices, these policies do not fully adhere to the requirements outlined by the Uniform Guidance. Subsequent to year-end, the University did perform the appropriate check for suspension and debarment for the applicable vendors which did not identify any such issues in that regard. Questioned Costs: Not applicable. Context: We compared the University?s policies and procedures to the applicable sections of the Uniform Guidance by reviewing three suppliers of a total of six suppliers subject to such testing and obtained the associated supporting documentation for our selection. We noted for the three suppliers tested, the University did not meet the requirement of verifying for vendor suspension or debarment. The sample was not statistically valid. Cause: The University?s policies were not reviewed to ensure all elements of Uniform Guidance were incorporated prior to entering into a contract with vendors for which federal funds were the source of the expenditure. Specifically, the University?s practices were not designed appropriately to check for suspension and debarment of the contractor utilized. Effect: The University is at risk of procuring goods and services that are not in compliance with the requirements outlined by Uniform Guidance, which increases the risk of federal expenditures being used improperly or the University entering into a covered transaction with a vendor that is debarred, suspended, or otherwise excluded. Recommendation: We recommend the University revise its policies and procedures to conform to the requirements of Uniform Guidance for the costs incurred with relevant awards, and implement procedures and controls to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Relevant employees should be trained on these new policies and procedures. Management?s response: The University agrees with the finding. Immediately upon being informed of the requirement to check for suspension and debarment, the University did complete such a review for all vendors with contracts over $10,000 for which all were found to be in good standing with the Federal government. Moving forward, the University has informed staff of this clause and has implemented a policy to review expenditures involving Federal funding over $10,000 with the SAM website prior to procurement.

Finding 2021-002: Significant Deficiency - Reporting Federal Program ? COVID-19 ? Education Stabilization Fund ? Institutional Portion Federal Agency ? U.S. Department of Education Pass-Through Entity ? Not Applicable CFDA Number ? 84.425F Federal Award Number ? P425F202752-20B Federal Award Year ? June 30, 2021 Criteria: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), directed institutions receiving funds under Section 18004 of the Act, to submit a report to the Secretary describing the use of funds distributed from the HEERF. The Department of Education (ED) requires institutions that received a HEERF 18004(a)(1) Institutional Aid Portion award to publicly post certain information on their website no later than 10 days after the end of each calendar quarter apart from the first report, which was due October 30, 2020, and the report covering the first quarter of calendar year 2021, which was due July 10, 2021. Condition/Context: The University posted their Quarterly Institutional Aid Portion Public Report on November 11, 2021, which was 134 days after the second calendar quarter of 2021. Questioned Costs: Not applicable. Cause: The University did not monitor deadlines for the HEERF reporting requirements. Effect: The University did not comply with the 10 day reporting requirement related to the HEERF Institutional Aid Portion. Recommendation: The University should assign an individual to track reporting requirements of awards to ensure the University is in compliance. Management's Response: The University agrees with the finding. An immediate review was completed of all HEERF reporting requirements and deadlines, with steps put in place to ensure future compliance with the deadlines.

Finding 2020-001: Enrollment Reporting Federal Program: Federal Direct Student Loans Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable CFDA Number: 84.268 Federal Award Number: P268K201780 Federal Award Year: June 30, 2020 Repeat of prior year finding 2019-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The change in student status for 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Context: Not applicable. Cause: The University followed its procedures for reporting student status changes, however two student records did not reflect a status change in NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Recommendation: The University should review its procedures to ensure that all enrollment status changes are updated accurately, including follow up after reporting to the clearinghouse to ensure the roster file was successfully received. Management's Response: The University reports enrollment statuses to the Clearinghouse on a monthly schedule. However, sometimes technical issues within the uploading of the enrollment data between the institutional system and the Clearinghouse result errors that require one or more attempts to fix, which in turn may result in a delay in updating the record within NSLDS. In consultation with other institutions, it appears these technical issues are experienced by those institutions as well. Moreover, there is also a time lag in summer reporting due to the optional nature of summer enrollment, which does not have to occur on a monthly pattern. The University will plan to place more emphasis on following the monthly reporting schedule. The University will monitor any technical issues and respond with timely corrections to the Clearinghouse. The Clearinghouse will update the NSLDS system to provide timely and accurate enrollment data and status changes for students who have attended or are attending the University.

Finding 2019-001: Significant Deficiency - Perkins Exit Counseling Federal Program - Federal Perkins Loan Program Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.038 Federal Award Number - P038A062460 Federal Award Year - June 30, 2019 Criteria: Title IV regulations (34 CFR 674.42) states an institution must ensure exit counseling is conducted with each borrower either in person or by interactive electronic means. If a borrower withdraws from the institution without the institution's prior knowledge or fails to complete an exit counseling session as required, the institution must ensure exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower's last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Condition/Context: We noted one instance where the University did not provide exit counseling materials to the borrower within 30 days after learning that the borrower withdrew from the University. The population size is 33 with a principal balance of $66,320. The sample size is 4 with a principal balance of $8,000. The University identified 4 additional students where exit counseling materials were not provided to borrowers. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide. Questioned Costs: Not applicable. Cause: The University overlooked sending out the exit counseling materials to the students in a timely manner. Effect: The students were not informed of his or her rights and responsibilities for their outstanding Perkins loans. Recommendation: The University should review its procedures to ensure that all graduating or withdrawing students who have a Perkins loan receive exit counseling materials within the required timeframe. Management?s Response: The University contracts with ECSI, a third-party servicer, who handles various notifications and processes student payments to the Perkins Loan program. This would include sending students the appropriate exit counseling materials within the required timeframe. It is, however, the University?s responsibility to notify ECSI when a student withdraws. While the University is no longer awarding Perkins Loan funds to students due to the ending of the program, the exit counseling requirement impacts those previous borrowers when they graduate or leave school. This finding was focused on in-term withdrawing students, in which the institution did not provide the notification to ECSI of the separation date in a timely way to allow them to send the exit counseling materials to the students. This oversight was likely the result of a turnover in the Student Billing department. As identified in the finding, the impact of this was 4-5 students in the past year. Procedures have been put in place to identify these in-term withdrawing students in a timely manner, and these procedures will be monitored regularly.The staff have been trained on procedures to identify the previous Perkins loan borrowers and to forward the records to ECSI. The Student Billing staff will review the loan histories of students who withdraw within the academic terms and will forward those student names to ECSI for the exit counseling follow-up. At the end of each term, a system report will be run to identify those students who have withdrawn or graduated, and the list of students who borrowed Perkins Loans will be forwarded to ECSI for the exit counseling follow-up.

Finding 2019-002: Significant Deficiency - Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Number - P268K191689 Federal Award Year - June 30, 2019 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide. Questioned Costs: Not applicable. Context: Not applicable. Cause: The University failed to follow its procedures for reporting student status changes. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Recommendation: The University should review its procedures to ensure that all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Management?s Response: The University reports enrollment statuses to the Clearinghouse on a monthly schedule. However, sometimes technical issues within the uploading of the enrollment data between the institutional system and the Clearinghouse result errors that require one or more attempts to fix, which in turn may result in a delay in updating the record within NSLDS. In consultation with other institutions, it appears these technical issues are experienced by those institutions as well. Moreover, there is also a time lag in summer reporting due to the optional nature of summer enrollment, which does not have to occur on a monthly pattern. The University will plan to place more emphasis on following the monthly reporting schedule. The University will monitor any technical issues and respond with timely corrections to the Clearinghouse. The Clearinghouse will update the NSLDS system to provide timely and accurate enrollment data and status changes for students who have attended or are attending the University.

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