EIN: 520805606
UEI: YPJCAUX4L6X1
Audited by: SB & COMPANY, LLC
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 11, 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 11, 2026 (9 days from today).
What is a management decision? →FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
During our testing of enrollment reporting, wereviewed the enrollment changes for studentsduring fiscal year 2024. We noted that for1 out of the16 students selected,the Universityreported the change in enrollment status 90 days after the date of determination. Criteria: Uniform Guidance requires that the institution report enrollment information under the Pell grantand the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, andverify student enrollment statuses, program information, and effective dates that appear on theEnrollment Reporting Roster file or on theEnrollment Maintenance page of theNSLDSProfessional Access. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the EnrollmentReporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002)mailboxes sent by ED via NSLDS. An institution determines how often it receives the EnrollmentReporting roster file with the default set at a minimum of every 60 days. Once received, theinstitution must updatefor changes in the dataelements for the CampusRecord and the ProgramRecord identified above, and submit the changes electronically through the batch method,spreadsheet submittal, or the NSLDS website. Cause: The University did not report the enrollment change in NSLDS timely. Effect: The University did not report the enrollment change timely which may impact the timeliness of repayment of Federal funds. Questioned Costs: Unknown. Recommendation: We recommend that the University establish procedures to ensure that enrollment changes are reported timely to NSLDS. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management’s approach to correct the finding.
Show full finding ▾Hide full finding ▴Condition: During our testing of enrollment reporting, wereviewed the enrollment changes for studentsduring fiscal year 2024. We noted that for1 out of the16 students selected,the Universityreported the change in enrollment status 90 days after the date of determination. Criteria: Uniform Guidance requires that the institution report enrollment information under the Pell grantand the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, andverify student enrollment statuses, program information, and effective dates that appear on theEnrollment Reporting Roster file or on theEnrollment Maintenance page of theNSLDSProfessional Access. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the EnrollmentReporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002)mailboxes sent by ED via NSLDS. An institution determines how often it receives the EnrollmentReporting roster file with the default set at a minimum of every 60 days. Once received, theinstitution must updatefor changes in the dataelements for the CampusRecord and the ProgramRecord identified above, and submit the changes electronically through the batch method,spreadsheet submittal, or the NSLDS website. Cause: The University did not report the enrollment change in NSLDS timely. Effect: The University did not report the enrollment change timely which may impact the timeliness of repayment of Federal funds. Questioned Costs: Unknown. Recommendation: We recommend that the University establish procedures to ensure that enrollment changes are reported timely to NSLDS. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management’s approach to correct the finding.
Compliance Deficiency over Special Tests and Provisions – Enrollment Reporting The University acknowledges that there was 1 out of the 16 students selected that the change in enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in March, 2024 the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an updated algorithm using data from the University’s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS’ database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal statutes. The addition of a Director of Financial Aid, December 2024, has further improved this process. Contact Person: Kim Wittler, AVP, Enrollment and Financial Aid Completion
2023-002
FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.
For the year ended June 30, 2023, the University did not complete a full close and review of the trial balance accounts by the start of the audit and multiple trial balances were generated. Net assets were not properly rolled at year end and the balance did not reconcile to the trial balance. Trial balance adjustments were booked after the close process was completed. Criteria: The University is responsible for maintaining an adequate system of internal controls over financial reporting in order to initiate, authorize, record and process and report financial data reliably in accordance with generally accepted accounting principles in the United States of America. Cause: The University did not have the June 30, 2023 financial records closed timely. Effect: The University’s 2023 audit was delayed, and journal entries were required. Questioned Costs: None Recommendation: We recommend management of the University implement close procedures at year end to complete a timely close with review prior to the start of the audit. Auditee’s Response and Corrective Action Plan: Management agrees with the finding. See the corrective action plan.
Show full finding ▾Hide full finding ▴Condition: For the year ended June 30, 2023, the University did not complete a full close and review of the trial balance accounts by the start of the audit and multiple trial balances were generated. Net assets were not properly rolled at year end and the balance did not reconcile to the trial balance. Trial balance adjustments were booked after the close process was completed. Criteria: The University is responsible for maintaining an adequate system of internal controls over financial reporting in order to initiate, authorize, record and process and report financial data reliably in accordance with generally accepted accounting principles in the United States of America. Cause: The University did not have the June 30, 2023 financial records closed timely. Effect: The University’s 2023 audit was delayed, and journal entries were required. Questioned Costs: None Recommendation: We recommend management of the University implement close procedures at year end to complete a timely close with review prior to the start of the audit. Auditee’s Response and Corrective Action Plan: Management agrees with the finding. See the corrective action plan.
Finding 2023-001 Significant Deficiency over Financial Reporting Management agrees with the finding. Corrective action plan follows. The College acknowledges that it did not complete a full close and review of the trial balance accounts by the start of the audit and that multiple trial balances were generated. It acknowledges that net assets were not properly rolled at year end and the balance did not reconcile to the trial balance, and that trial balance adjustments were booked after the close process was completed. Management has reviewed its yearend close procedures and has implemented the following guidelines to ensure an accurate and timely close: The College can better prepare for yearend close by reinforcing its month end close procedures. Month end close procedures and reconciliations were inconsistent throughout the year. The College has established a checklist of monthly processes, recurring journal entries, and the support needed to complete the reconciliation process. Reconciling accounts on a monthly basis allows for the identification and correction of errors in a timely manner. Monthly reconciliations are kept on a shared network and can be accessed by all Business Office team members. The VP of Finance will review monthly bank reconciliations to ensure accuracy and timeliness. Net Assets have been reviewed and agreed to the prior year audit report. The College has a detailed yearend checklist which includes a list of yearend journal entries, and a detailed list of the schedules provided to auditors. The College will prepare a close schedule identifying important dates, activities and responsibilities to ensure items are completed in a timely manner and that all necessary deadlines are met. Yearend schedules are on a shared network drive so that progress and accuracy can be monitored. The VP of Finance will hold regular meetings with the Business Office team to monitor yearend close progress. Once the yearend close has been established, all reports will be reviewed and compared to previous year’s figures to identify any unexpected changes, and agreed to the final trial balance prior to uploading to the audit portal. No adjustments will be allowed once the trial balance has been finalized without consultation with the auditors. The Business Office team will continue to reevaluate any processes or systems used during the previous yearend closes and update them as needed, such as setting up new accounts, reviewing current statements for accuracy, or revising account coding. Contact Person: Kathleen Werner, Interim VP Finance Completion Date: June 30, 2024
During our testing of enrollment reporting, we reviewed the enrollment changes for students during fiscal year 2023. We noted that for 1 out of the 14 students selected, the University reported the change in enrollment status 64 days after the date of determination. Criteria: Uniform Guidance requires that the institution report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Cause: The University did not report the enrollment change in NSLDS timely. Effect: The University did not report the enrollment change timely. Questioned Costs: Unknown. Recommendation: We recommend that the University establish procedures to ensure that enrollment changes are reported timely to NSLDS. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management’s approach to correct the finding. Auditor’s Conclusion: Finding remains as stated.
Show full finding ▾Hide full finding ▴Condition: During our testing of enrollment reporting, we reviewed the enrollment changes for students during fiscal year 2023. We noted that for 1 out of the 14 students selected, the University reported the change in enrollment status 64 days after the date of determination. Criteria: Uniform Guidance requires that the institution report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Cause: The University did not report the enrollment change in NSLDS timely. Effect: The University did not report the enrollment change timely. Questioned Costs: Unknown. Recommendation: We recommend that the University establish procedures to ensure that enrollment changes are reported timely to NSLDS. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management’s approach to correct the finding. Auditor’s Conclusion: Finding remains as stated.
Finding 2023-002 Significant Deficiency over Special Tests and Provisions - Enrollment Reporting The University acknowledges that there was 1 out of the 14 students selected that the change in , - 0 enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in 2024 the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an updated algorithm using data from the University’s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS' database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal status. Contact Person: Kim Wittler, AVP, Enrollment and Financial Aid Completion Date: March 1, 2024
2022-001
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
During our testing of enrollment reporting, we reviewed the enrollment changes for students during fiscal year 2022. We noted that for 2 out of the 25 students selected, the institution reported the change in enrollment status 186 days after the date of determination. Criteria: Uniform Guidance requires that the institution report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Cause: The University did not report the enrollment change in NSLDS timely. Effect: The University did not report the enrollment change timely. Questioned Costs: None.Recommendation: We recommend that the University establish procedures to ensure that enrollment changes are reported timely to NSLDS. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management?s approach to correct the finding. Auditor?s Conclusion: Finding remains as stated.
Show full finding ▾Hide full finding ▴Finding 2022-001 Capitol Technology University U.S. Department of Education (ED) Student Financial Assistance Cluster Assistance Listing No. 84.007 Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing No. 84.033 Federal Work- Study Program (FWS) Assistance Listing No. 84.038 Federal Perkins Loan (FPL) ? Federal Capital Contributions Assistance Listing No. 84.063 Federal Pell Grant Program (Pell) Assistance Listing No. 84.268 Federal Direct Student Loans (Direct Loan) Compliance Deficiency over Special Tests and Provisions ? Enrollment Reporting Repeat Finding: No Condition: During our testing of enrollment reporting, we reviewed the enrollment changes for students during fiscal year 2022. We noted that for 2 out of the 25 students selected, the institution reported the change in enrollment status 186 days after the date of determination. Criteria: Uniform Guidance requires that the institution report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Cause: The University did not report the enrollment change in NSLDS timely. Effect: The University did not report the enrollment change timely. Questioned Costs: None.Recommendation: We recommend that the University establish procedures to ensure that enrollment changes are reported timely to NSLDS. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management?s approach to correct the finding. Auditor?s Conclusion: Finding remains as stated.
The University acknowledges that there were 2 out of the 25 students selected that the change in enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in January 2023, the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an algorithm using data from the University?s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS? database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal statutes.
FAC accepted this audit on April 17, 2022 — management decision was due October 17, 2022.
During our testing of return of Title IV funds, we reviewed the calculation of return of Title IV funds of 5 students who had withdrawn during the fiscal year 2021. We noted that for 2 out of the 5 students selected, the amount returned was not accurately calculated and therefore, amount returned was less than what should have been returned. The amount not returned for the 2 students was $703. Criteria: Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control ? Integrated Framework (COSO Report), published by the United States Government Accountability Office?s Standards for Internal Control in the Federal Government. The COSO Report provides a framework for organizations to design, implement, and evaluate controls that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 34 CFR 668.22(a)(1) through (a)(5): When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement. Per 34 CFR 668.22(e)(2): Calculation of the Amount of Title IV Assistance Earned The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. Per 34 CFR 668.22(e): The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew. Per 34 CFR 668.22(f): Percentage of Payment Period or Period of Enrollment Completed The percentage of the payment period completed or period of enrollment completed is determined in the case of a program that is measured in (1) credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student?s withdrawal date; or (2) clock hours, by dividing the total number of clock hours in the payment period or period of enrollment into the number of clock hours scheduled to be completed as of the student?s withdrawal date. The total number of calendar days in a payment or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least five consecutive calendar days (including module programs that a student is not required to attend for five consecutive calendar days) and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Cause: The 117 days in the semester were used to calculate percentage of payment period, where the semester had only 109 days. The percentage of payment period and therefore, the amount the University should return was not calculated accurately. The University returned less funds than it should have returned. Effect: The University returned less funds than it should have returned. Questioned Costs: Unknown. Recommendation: We recommend that the University establish procedures to ensure that return of Title IV are calculated using the correct total days in the semester following the Federal guidelines. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management?s approach to correct the finding. Auditor?s Conclusion: Finding remains as stated.
Show full finding ▾Hide full finding ▴Condition: During our testing of return of Title IV funds, we reviewed the calculation of return of Title IV funds of 5 students who had withdrawn during the fiscal year 2021. We noted that for 2 out of the 5 students selected, the amount returned was not accurately calculated and therefore, amount returned was less than what should have been returned. The amount not returned for the 2 students was $703. Criteria: Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control ? Integrated Framework (COSO Report), published by the United States Government Accountability Office?s Standards for Internal Control in the Federal Government. The COSO Report provides a framework for organizations to design, implement, and evaluate controls that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Per 34 CFR 668.22(a)(1) through (a)(5): When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement. Per 34 CFR 668.22(e)(2): Calculation of the Amount of Title IV Assistance Earned The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours. Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student?s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. Per 34 CFR 668.22(e): The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew. Per 34 CFR 668.22(f): Percentage of Payment Period or Period of Enrollment Completed The percentage of the payment period completed or period of enrollment completed is determined in the case of a program that is measured in (1) credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student?s withdrawal date; or (2) clock hours, by dividing the total number of clock hours in the payment period or period of enrollment into the number of clock hours scheduled to be completed as of the student?s withdrawal date. The total number of calendar days in a payment or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least five consecutive calendar days (including module programs that a student is not required to attend for five consecutive calendar days) and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Cause: The 117 days in the semester were used to calculate percentage of payment period, where the semester had only 109 days. The percentage of payment period and therefore, the amount the University should return was not calculated accurately. The University returned less funds than it should have returned. Effect: The University returned less funds than it should have returned. Questioned Costs: Unknown. Recommendation: We recommend that the University establish procedures to ensure that return of Title IV are calculated using the correct total days in the semester following the Federal guidelines. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management?s approach to correct the finding. Auditor?s Conclusion: Finding remains as stated.
Finding 2021-001 Auditee?s Corrective Action Plan The University immediately corrected the withdraw calculation for the two students identified by the auditors and processed the refunds totaling $703 on February 11, 2022. The auditors were given documentation of the revised refunds. As of February 14, 2022, the university modified its business practice for processing withdraw calculations to require a second review in the Financial Aid Office prior to sending the calculation to the Business Office and processing any refund. The process is as follows: The withdraw form is received electronically upon student submission by Financial Aid, Business Office and Registration and Records. The Director of Financial Aid is responsible for processing all withdraws to include completing the Return to Title IV Worksheet, processing grant and loan adjustments to the Business Office and COD along with updating NSDLS. Before submitting adjustments the Return of Title IV Worksheet will be reviewed by the AVP of Enrollment and Financial Aid to provide a second review of the calculation. Both reviewers will initial and date the form. The Director of Financial Aid will then complete the withdraw process of notifying the Business Office of refunds, processing the return of funds to COD and updating NSLDS. This revised practice will ensure compliance with the Return of Title IV Funds. Contact Person: Kim Wittler, AVP, Enrollment and Financial Aid Completion Date: March 4, 2022
FAC accepted this audit on February 8, 2021 — management decision was due August 8, 2021.
Per Uniform Guidance: Under the FFEL and Direct Loan programs, schools must complete and return within 30 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR ? 682.610(c): A school shall ? (1) Upon receipt of a student status confirmation report form from the Secretary or a similar student status confirmation report form from any guaranty agency, complete and return that report within 30 days of receipt to the Secretary or the guaranty agency, as appropriate; and (2) Unless it expects to submit its next student status confirmation report to the Secretary or the guaranty agency within the next 60 days, notify the guaranty agency or lender within 30 days ? (i) If it discovers that a Stafford, Supplemental Loan for Students (SLS), or Parent Loan for Undergraduate Students (PLUS) loan has been made to or on behalf of a student who enrolled at that school, but who has ceased to be enrolled on at least a half-time basis; (ii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a student who has been accepted for enrollment at that school, but who failed to enroll on at least a half-time basis for the period for which the loan was intended; (iii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a full-time student who has ceased to be enrolled on a full-time basis; or (iv) If it discovers that a student who is enrolled and who has received a Stafford or SLS loan has changed his or her permanent address. Cause: For the 3 selections that were not reported timely, the students were not included on the roster within the 60-day period, so the changes were reported late.Effect: The changes in student?s enrollment were not reported timely to the NSLDS database, thus, repayment dates, grace periods, and deferments may not be properly determined. Reporting of graduated statuses is critical to the protection of a student?s interest subsidy and initiation of repayment periods. The graduated status may impact the amount of the interest subsidy on the student?s current loans.
Show full finding ▾Hide full finding ▴Per Uniform Guidance: Under the FFEL and Direct Loan programs, schools must complete and return within 30 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR ? 682.610(c): A school shall ? (1) Upon receipt of a student status confirmation report form from the Secretary or a similar student status confirmation report form from any guaranty agency, complete and return that report within 30 days of receipt to the Secretary or the guaranty agency, as appropriate; and (2) Unless it expects to submit its next student status confirmation report to the Secretary or the guaranty agency within the next 60 days, notify the guaranty agency or lender within 30 days ? (i) If it discovers that a Stafford, Supplemental Loan for Students (SLS), or Parent Loan for Undergraduate Students (PLUS) loan has been made to or on behalf of a student who enrolled at that school, but who has ceased to be enrolled on at least a half-time basis; (ii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a student who has been accepted for enrollment at that school, but who failed to enroll on at least a half-time basis for the period for which the loan was intended; (iii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a full-time student who has ceased to be enrolled on a full-time basis; or (iv) If it discovers that a student who is enrolled and who has received a Stafford or SLS loan has changed his or her permanent address. Cause: For the 3 selections that were not reported timely, the students were not included on the roster within the 60-day period, so the changes were reported late.Effect: The changes in student?s enrollment were not reported timely to the NSLDS database, thus, repayment dates, grace periods, and deferments may not be properly determined. Reporting of graduated statuses is critical to the protection of a student?s interest subsidy and initiation of repayment periods. The graduated status may impact the amount of the interest subsidy on the student?s current loans.
Recommendation: We recommend that the University establish procedures to ensure that enrollment status changes are tracked frequently throughout the year and ensure timely reporting of the enrollment status changes to NSLDS database. Views of Responsible Officials: Refer to the prior year Corrective Action Plan for management?s approach to correct the finding. Management agrees with the finding. Auditor?s Conclusion: Finding remains as stated. We noted the corrective action plan was put in place in March 2020. The 3 exceptions occurred prior to the implementation of the corrective action plan.
2019-001
FAC accepted this audit on April 29, 2020 — management decision was due October 29, 2020.
During our testing of student enrollment reporting, we reviewed the enrollment status of 40 students who had changes in enrollment status. We noted that for 3 out of the 40 students selected, students? statuses were not updated timely to the National Student Loan Data System (NSLDS). From the date the institution determined the student had a change in enrollment status, to the date that the enrollment status change was reported to NSLDS, exceeded the 60-day reporting timeframe. For 6 out of the 40 students, the students? change in statuses was not processed by NSLDS. As a result, the institution exceeded the 60-day reporting timeframe to report the change to NSLDS. Criteria: Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control ? Integrated Framework (COSO Report), published by the United States Government Accountability Office?s Standards for Internal Control in the Federal Government. The COSO Report provides a framework for organizations to design, implement, and evaluate controls that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Finding 2019-001 (continued) Per Uniform Guidance: Under the FFEL and Direct Loan programs, schools must complete and return within 30 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR ? 682.610(c): A school shall ? (1) Upon receipt of a student status confirmation report form from the Secretary or a similar student status confirmation report form from any guaranty agency, complete and return that report within 30 days of receipt to the Secretary or the guaranty agency, as appropriate; and (2) Unless it expects to submit its next student status confirmation report to the Secretary or the guaranty agency within the next 60 days, notify the guaranty agency or lender within 30 days ? (i) If it discovers that a Stafford, Supplemental Loan for Students (SLS), or Parent Loan for Undergraduate Students (PLUS) loan has been made to or on behalf of a student who enrolled at that school, but who has ceased to be enrolled on at least a half-time basis; (ii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a student who has been accepted for enrollment at that school, but who failed to enroll on at least a half-time basis for the period for which the loan was intended; (iii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a full-time student who has ceased to be enrolled on a full-time basis; or (iv) If it discovers that a student who is enrolled and who has received a Stafford or SLS loan has changed his or her permanent address. Cause: For the 3 selections that were not reported timely, the student was not included on the roster within the 60-day period, so the change was reported late. For the 6 selections that were not reported, management stated that the change of status was reported directly to the NSLDS; however, SBC did not see a change in status for those students in the COD system. Finding 2019-001 (continued) Effect: The change in student?s enrollment is not reported timely to the NSLDS database, thus, repayment date, grace period, and deferment may not be properly determined. Reporting of graduated statuses is critical to the protection of a student?s interest subsidy and initiation of repayment periods. The graduated status may impact the amount of the interest subsidy on the student?s current loans. Questioned Costs: None. Recommendation: We recommend that the University establish procedures to ensure that enrollment status changes are tracked frequently throughout the year and ensure timely reporting of the enrollment status change to NSLDS database. Views of Responsible Officials: Management agrees with the finding. For the 6 out of 40 students where the status was not received by NSLDS, management believes that the student?s change in status were updated by the University according to the documentation received but were not captured by NSLDS. Refer to the Corrective Action Plan for management?s approach to correct the finding. Auditor?s Conclusion: Finding remains as stated.
Show full finding ▾Hide full finding ▴Condition: During our testing of student enrollment reporting, we reviewed the enrollment status of 40 students who had changes in enrollment status. We noted that for 3 out of the 40 students selected, students? statuses were not updated timely to the National Student Loan Data System (NSLDS). From the date the institution determined the student had a change in enrollment status, to the date that the enrollment status change was reported to NSLDS, exceeded the 60-day reporting timeframe. For 6 out of the 40 students, the students? change in statuses was not processed by NSLDS. As a result, the institution exceeded the 60-day reporting timeframe to report the change to NSLDS. Criteria: Uniform Guidance requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal award. The characteristics of internal controls are presented in the context of the components of internal controls discussed in Internal Control ? Integrated Framework (COSO Report), published by the United States Government Accountability Office?s Standards for Internal Control in the Federal Government. The COSO Report provides a framework for organizations to design, implement, and evaluate controls that will facilitate compliance with the requirements of Federal laws, regulations, and program compliance requirements. Finding 2019-001 (continued) Per Uniform Guidance: Under the FFEL and Direct Loan programs, schools must complete and return within 30 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR ? 682.610(c): A school shall ? (1) Upon receipt of a student status confirmation report form from the Secretary or a similar student status confirmation report form from any guaranty agency, complete and return that report within 30 days of receipt to the Secretary or the guaranty agency, as appropriate; and (2) Unless it expects to submit its next student status confirmation report to the Secretary or the guaranty agency within the next 60 days, notify the guaranty agency or lender within 30 days ? (i) If it discovers that a Stafford, Supplemental Loan for Students (SLS), or Parent Loan for Undergraduate Students (PLUS) loan has been made to or on behalf of a student who enrolled at that school, but who has ceased to be enrolled on at least a half-time basis; (ii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a student who has been accepted for enrollment at that school, but who failed to enroll on at least a half-time basis for the period for which the loan was intended; (iii) If it discovers that a Stafford, SLS, or PLUS loan has been made to or on behalf of a full-time student who has ceased to be enrolled on a full-time basis; or (iv) If it discovers that a student who is enrolled and who has received a Stafford or SLS loan has changed his or her permanent address. Cause: For the 3 selections that were not reported timely, the student was not included on the roster within the 60-day period, so the change was reported late. For the 6 selections that were not reported, management stated that the change of status was reported directly to the NSLDS; however, SBC did not see a change in status for those students in the COD system. Finding 2019-001 (continued) Effect: The change in student?s enrollment is not reported timely to the NSLDS database, thus, repayment date, grace period, and deferment may not be properly determined. Reporting of graduated statuses is critical to the protection of a student?s interest subsidy and initiation of repayment periods. The graduated status may impact the amount of the interest subsidy on the student?s current loans. Questioned Costs: None. Recommendation: We recommend that the University establish procedures to ensure that enrollment status changes are tracked frequently throughout the year and ensure timely reporting of the enrollment status change to NSLDS database. Views of Responsible Officials: Management agrees with the finding. For the 6 out of 40 students where the status was not received by NSLDS, management believes that the student?s change in status were updated by the University according to the documentation received but were not captured by NSLDS. Refer to the Corrective Action Plan for management?s approach to correct the finding. Auditor?s Conclusion: Finding remains as stated.
While the University acknowledges the enrollment status for 3 out of 40 selected students was not accurate. The University maintains that and provided evidence that the statuses were updated on the NSLDS spreadsheet and loaded for 6 out of 40 selected students. NSLDS for an unknown reason, according to NSLDS help desk, did not capture the updates for the 6 students noted. Through exhaustive conversations with NSLDS, it has been determined that their system does not have the capability to determine updates processed at the student level when using the spreadsheet upload method of reporting. Effective with the Student Enrollment report received from NSLDS on March 18, 2020, the business practice has changed to ensure accurate and timely reporting of students? enrollment status. Upon receipt, the file is updated by an algorithm using data from the University?s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS? database and are removed from the resulting spreadsheet produced by NSLDS. A screen shot of accepted records is maintained showing number of records received and accepted. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. The records listed on the resulting spreadsheet are updated manually on NSLDS? website as opposed to utilizing the spreadsheet upload. This is to ensure accurate enrollment status. The manual entries are updated in real-time. Additionally, the University is updating enrollment status changes manually upon receipt of Action. Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal statutes. Looking forward the University plans on investigating batch reporting to ensure an audit-trail of modifications to the student record that is not available using the spreadsheet method which caused this finding.
For the fiscal year ended June 30, 2019, the University did not perform a risk assessment review or document safeguards for each risk identified from its risk assessment. Criteria: The Compliance Supplement requires the University to protect student financial aid information. Further it requires the University to have a designated individual to coordinate the information security program, perform a risk assessment for the areas as noted in the Compliance Supplement, and document a safeguard for each risk identified Cause: The University did not complete the Single Audit Compliance Supplement requirements for the fiscal year ended June 30, 2019, because of the timing of when the Compliance Supplement was issued. Effect: Since the University did not have a risk assessment review process in place and did not document safeguards for each risk identified, there is increased risk exposure that unidentified risk could increase exposure to disruption in the availability of the server supporting the financial applications or result in unauthorized access to the University?s internal network; lack of cybersecurity policies and procedures may result to inappropriate security or cyber events handling practices; and potential vulnerabilities may not be detected and remediated on a timely basis.Questioned Costs: None. Recommendation: We recommend the University perform a risk assessment, and document safeguards for each risk identified from its risk assessment. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management?s plan. Auditor?s Conclusion: Finding remains as stated.
Show full finding ▾Hide full finding ▴Condition: For the fiscal year ended June 30, 2019, the University did not perform a risk assessment review or document safeguards for each risk identified from its risk assessment. Criteria: The Compliance Supplement requires the University to protect student financial aid information. Further it requires the University to have a designated individual to coordinate the information security program, perform a risk assessment for the areas as noted in the Compliance Supplement, and document a safeguard for each risk identified Cause: The University did not complete the Single Audit Compliance Supplement requirements for the fiscal year ended June 30, 2019, because of the timing of when the Compliance Supplement was issued. Effect: Since the University did not have a risk assessment review process in place and did not document safeguards for each risk identified, there is increased risk exposure that unidentified risk could increase exposure to disruption in the availability of the server supporting the financial applications or result in unauthorized access to the University?s internal network; lack of cybersecurity policies and procedures may result to inappropriate security or cyber events handling practices; and potential vulnerabilities may not be detected and remediated on a timely basis.Questioned Costs: None. Recommendation: We recommend the University perform a risk assessment, and document safeguards for each risk identified from its risk assessment. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan for management?s plan. Auditor?s Conclusion: Finding remains as stated.
The University has conducted a risk assessment during the week of February 24, 2020, and documented safeguards for each risk identified.
FAC accepted this audit on March 25, 2018 — management decision was due September 25, 2018.
FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
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