EIN: 540573801
UEI: FPZ9KW2KCUF7
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 27, 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 August 27, 2026 (3 days ago).
What is a management decision? →2025-001: NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 60 students, which is a statistically valid sample, we noted 4 instances where the date of the student’s status change did not match between the University’s records and NSLDS, 1 instance where the student's enrollment status was not certified within 60 days, 1 instance where the program enrollment status did not match the campus enrollment status, 1 instance where the program enrollment effective date did not match the campus enrollment effective date, and 1 instance where the student's information was not reported to NSLDS. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, finding 2024-003. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2025-001: NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 60 students, which is a statistically valid sample, we noted 4 instances where the date of the student’s status change did not match between the University’s records and NSLDS, 1 instance where the student's enrollment status was not certified within 60 days, 1 instance where the program enrollment status did not match the campus enrollment status, 1 instance where the program enrollment effective date did not match the campus enrollment effective date, and 1 instance where the student's information was not reported to NSLDS. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, finding 2024-003. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were primarily driven by the University’s transition to a new Student Information System (Workday), including the Workday-delivered National Student Clearinghouse (NSC) integrations. These constraints resulted in delays and gaps in enrollment reporting processes, increased processing timelines with the National Student Clearinghouse (NSC), and impacted the timely and accurate transmission of enrollment data to the National Student Loan Data System (NSLDS). In response, Marymount University has developed a formal Standard Operating Procedure (SOP) for National Student Clearinghouse reporting and has begun implementing these procedures during the 2025–2026 academic year. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: Completed December 2025.
2024-001
2025-002: Return of Title IV Funds Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria or Specific Requirement: In accordance with 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. Condition/Context: During our testing of 26 students, which is a statistically valid sample, we noted 1 instance where the student's return of Title IV funds was not calculated and returned to the Title IV program correctly. Questioned Costs: $1,053.49 Cause: The University’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: The University is not compliant with federal requirements and their internal procedures. Repeat Finding: No. Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2025-002: Return of Title IV Funds Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria or Specific Requirement: In accordance with 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. Condition/Context: During our testing of 26 students, which is a statistically valid sample, we noted 1 instance where the student's return of Title IV funds was not calculated and returned to the Title IV program correctly. Questioned Costs: $1,053.49 Cause: The University’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: The University is not compliant with federal requirements and their internal procedures. Repeat Finding: No. Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was driven by incorrect MSMS program start and end dates configured in the University’s new Student Information System (Workday). When processing Return of Title IV (R2T4) calculations, Workday relies on the program start and end dates stored in the system. Due to these dates being incorrect, the R2T4 process calculated an inaccurate number of days enrolled, which resulted in an incorrect earned percentage of Title IV aid and, consequently, an incorrect amount of aid the student was eligible to retain. To address this issue, the University has implemented internal controls to review and verify the start and end dates of each academic year in Workday prior to the start of each semester. In addition, an internal control has been added to ensure the start and end dates of each academic year are reviewed and validated as part of the Return of Title IV processing. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: Completed December 2025.
2025-003: FISAP Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: Per U.S. Department of Education guidelines for the Fiscal Operations Report and Application to Participate (FISAP), institutions must accurately report tuition and fees in Part II, Section E, Line 22 based on official institutional records and applicable accounting standards. Condition/Context: During our testing of the FISAP submission for the SFA fund, we noted that Part II (Application), Section E, Line 22: Total Tuition and Fees did not contain correct information. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information of institutional financial data is reported to the Department of Education, which may trigger additional compliance reviews. Repeat Finding: No. Recommendation: We recommend the University review its reporting procedures to ensure that key line items are reviewed and accurately reported to Department of Education as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2025-003: FISAP Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: Per U.S. Department of Education guidelines for the Fiscal Operations Report and Application to Participate (FISAP), institutions must accurately report tuition and fees in Part II, Section E, Line 22 based on official institutional records and applicable accounting standards. Condition/Context: During our testing of the FISAP submission for the SFA fund, we noted that Part II (Application), Section E, Line 22: Total Tuition and Fees did not contain correct information. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information of institutional financial data is reported to the Department of Education, which may trigger additional compliance reviews. Repeat Finding: No. Recommendation: We recommend the University review its reporting procedures to ensure that key line items are reviewed and accurately reported to Department of Education as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items are reviewed and accurately reported to Department of Education as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding resulted from inaccuracies introduced through enhancements made to a Workday-delivered report, which ultimately did not produce correct information. Going forward, we will review and validate the Workday report to ensure it aligns with Student Accounts’ reports and accurately reflects tuition and fees for the academic year. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: June 2026 If the U.S. Department of Education have questions regarding this plan, please contact the individual(s) noted above.
FAC accepted this audit on February 27, 2025 — management decision was due August 27, 2025.
Under an institution’s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform and document a risk assessment that addresses certain of the elements noted in 16 CFR 314.4 (b) which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the University, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: Yes, finding 2023-002. Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires institutions to explain their informationsharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). Condition: Under an institution’s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform and document a risk assessment that addresses certain of the elements noted in 16 CFR 314.4 (b) which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the University, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: Yes, finding 2023-002. Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: Please refer to the attached corrective action plan.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has prepared a separate Corrective Action Plan document in response to this finding due to the sensitivity. Each requirement noted as a deficiency within the finding is address separately and appropriate response is being taken. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan completed on February 18, 2025.
2023-002
Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 40 students, which is a statistically valid sample, we noted 4 instances where the student's enrollment status was not certified within 60 days and 4 instances where the date of the student’s status change did not match between the University’s records and NSLDS. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, finding 2023-003. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 40 students, which is a statistically valid sample, we noted 4 instances where the student's enrollment status was not certified within 60 days and 4 instances where the date of the student’s status change did not match between the University’s records and NSLDS. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, finding 2023-003. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings stemmed from how the Student Information System (SIS) transmitted graduation dates and the accuracy of submission files. Our previous SIS was unable to determine the correct graduation dates, leading to incorrect data uploads to the National Student Clearinghouse (NSC). We reviewed the NSC error report and made individual corrections. Unfortunately, we missed the data transmission at the beginning of the month and had to wait for the corrections to be sent to the National Student Loan Data System (NSLDS) the following month. Additionally, we did not conduct a comprehensive review of the file to ensure that all data matched after the upload. Marymount has transitioned to a new SIS starting in Fall 2024. We are working closely with the NSC during this transition to provide more timely and accurate data. We have also improved our processes by having multiple staff members review data files before posting them to the NSC, ensuring that every data point is correct. Furthermore, we have joined user groups related to our SIS and NSC reports to stay informed about changes made by the SIS vendor and to be aware of potential complications faced by other universities. Any errors identified during the data upload to the NSC will be corrected within 2-3 business days. This process will ensure that the enrollment status is certified within 60 days and that all dates match. If we are unable to update the NSC before the file is submitted to the NSLDS, we will collaborate with our Financial Aid department to manually update the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: March 2025
2023-003
Criteria or Specific Requirement: For recipients of research and development grants, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: For recipients of research and development grants, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.
Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Midway through the fiscal year, we introduced a new process involving multiple layers of approval before a drawdown is executed. The drawdown calculation is done either by the Senior Accountant or Grant Manager and sent to either the Grant Manager (if prepared by the Senior Accountant), or Controller (if prepared by the Grant Manager) for review and approval. If additional information is needed, the approver sends the request back for updating and recalculation. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: Action taken during April 2024
FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.
Under an institution’s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform and document a risk assessment that addresses certain of the elements noted in 16 CFR 314.4 (b) which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the University, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2023–002: Gramm-Leach-Bliley Act Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). Condition: Under an institution’s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform and document a risk assessment that addresses certain of the elements noted in 16 CFR 314.4 (b) which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the University, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: Please refer to the attached corrective action plan.
Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Acquired Isora GRC, a software tool to facilitate and document compliance with GLBA requirements and the corresponding NIST 800-171 information security framework. Management has also created an Enterprise Risk Management Committee which will incorporate compliance with GLBA as a top priority. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan by June 1, 2024, including decision regarding use of a third party or in-house resources to perform the risk assessment. Completion of 90% of action plan items within one year.
2023-003: NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 40 students, which is a statistically valid sample, we noted 2 instances where the student's enrollment status was not certified within 60 days, 5 instances where the effective date of a student status change was improperly reported at the program-level and campus-level record, and 2 instances where the student status was incorrectly reported. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2023-003: NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 40 students, which is a statistically valid sample, we noted 2 instances where the student's enrollment status was not certified within 60 days, 5 instances where the effective date of a student status change was improperly reported at the program-level and campus-level record, and 2 instances where the student status was incorrectly reported. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.
Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were a result of data entry or date errors. Moving forward the Registrar's Office will have a second staff member review files prior to submission to ensure the accuracy of the submission to the National Student Clearinghouse. The Registrar's Office will notify Financial Aid of NSC submission dates so the FA team can verify accuracy in NSLDS. Name(s) of the contact person(s) responsible for corrective action: Dr. Meghan Arias, University Registrar, 703-284-1526 Planned completion date for corrective action plan: 3/24/24 - date of next file submission
2023–004: 14 Day Credit Balances Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition/Context: Through our testing of 18 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period. Questioned Costs: None Cause: The refunds for the students in question were not completed within the 14-day period for one of the following reasons – (1) the payment file was created timely but had an error that needed correction and caused payment delay and/or (2) payment was on or around a holiday and the University’s accounts payable personnel were out of office. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by U.S. Department of Education regulations. Repeat Finding: No Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Views of responsible officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2023–004: 14 Day Credit Balances Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Numbers: 84.007, 84.268, 84.033, 84.038, 84.063 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition/Context: Through our testing of 18 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period. Questioned Costs: None Cause: The refunds for the students in question were not completed within the 14-day period for one of the following reasons – (1) the payment file was created timely but had an error that needed correction and caused payment delay and/or (2) payment was on or around a holiday and the University’s accounts payable personnel were out of office. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by U.S. Department of Education regulations. Repeat Finding: No Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Views of responsible officials: Please refer to the attached corrective action plan.
Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refunds will be processed weekly allowing enough time to correct any errors before the end of the 14 day period. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: March 2024
2023–005: Over-Award of Financial Aid Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.268 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition/Context: During our testing, we noted 1 instance out of 25 students tested where the subsidized Stafford loan awarded to the student was over the maximum amount they were eligible for. Questioned Costs: $1,000 Cause: The University did not appropriately determine the student's level of education when awarding the Subsidized Stafford Loan. Effect: Those students that were over-awarded subsidized loans were awarded incorrectly as they were not eligible for the specific awarded amount. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Views of responsible officials: Please refer to the attached corrective action plan.
Show full finding ▾Hide full finding ▴2023–005: Over-Award of Financial Aid Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.268 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition/Context: During our testing, we noted 1 instance out of 25 students tested where the subsidized Stafford loan awarded to the student was over the maximum amount they were eligible for. Questioned Costs: $1,000 Cause: The University did not appropriately determine the student's level of education when awarding the Subsidized Stafford Loan. Effect: Those students that were over-awarded subsidized loans were awarded incorrectly as they were not eligible for the specific awarded amount. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Views of responsible officials: Please refer to the attached corrective action plan.
Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Marymount University experienced high turnover in the Office of Financial Aid from the Director down to the counselor position in the 22-23 academic year. In that transition, Attain partners was contracted in late 2022 as interim staffing. For the one student in the finding that was found to have received a grade level 3 loan instead of level 2 based on the number of credits completed, research found that a rule setting in Ellucian Colleague caused the student to be auto-packaged at level 3 and it was accepted and disbursed in COD (Common Origination & Disbursement). Moving forward, Attain Partners will work with Marymount IT to update any rule settings to catch this issue and provide the Marymount Financial Aid office with internal controls that will catch any issues for the current aid year. Management notes that this issue arose due to a software programming error tied to an updated rule setting in Ellucian Colleague. Moving forward staff in Financial Aid will work in tandem with colleagues in Information Technology to review all updated rule setting in order to catch and address potential miscalculations. Name(s) of the contact person(s) responsible for corrective action: Meghan Sutton, Interim Director of Financial Aid, 703.284.1532 Planned completion date for corrective action plan: May 2024
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
We requested DL reconciliations for the months of September 2021 and February 2022. Cause: The University could not provide completed DL reconciliations for these months.
Show full finding ▾Hide full finding ▴Criteria: Institutions are required to reconcile all Direct Loan (DL) disbursements and submit required records to the Department of Education through the Common Origination and Disbursement (COD) system. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files monthly to the institution?s financial records (?DL reconciliations?). Condition: We requested DL reconciliations for the months of September 2021 and February 2022. Cause: The University could not provide completed DL reconciliations for these months.
Marymount University administration acknowledges the findings from the 2021-2022 UG Audit. Marymount administration takes the findings very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: ? Marymount University has experienced a turnover in the Office of Financial Aid from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. ? In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to assure compliance with Title IV regulations, including Direct Loan reconciliation. ? Attain Partners has fully reconciled the 2021-2022 Federal Direct Loan funds and has put processes in place in conjunction with the Marymount University Financial Affairs Division to assure monthly and final reconciliation going forward. ? Attain Partners will be reviewing existing processes related to student financial aid. As an outcome of this review the processes and schedule will be fully documented and implemented as documented.
2021-001
Based on professional judgement, we selected six students who received all failing grades for testing and all students had documentation of last date of attendance at an academically related activity. Three of the six student?s documented last date of attendance at an academically related activity was before the 60% point of the payment period, for which a refund would possibly be required if the student did not attend any class through the end of the period. Cause: The University has a grading policy that includes an F, failure to meet standards, and FA, failure primarily due to poor or non-attendance. Instructors enter a last date of attendance if the student failed to attend class; however, there is no written policy to rely which instructors are required to enter a last date of attendance.
Show full finding ▾Hide full finding ▴Criteria: A school must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: Based on professional judgement, we selected six students who received all failing grades for testing and all students had documentation of last date of attendance at an academically related activity. Three of the six student?s documented last date of attendance at an academically related activity was before the 60% point of the payment period, for which a refund would possibly be required if the student did not attend any class through the end of the period. Cause: The University has a grading policy that includes an F, failure to meet standards, and FA, failure primarily due to poor or non-attendance. Instructors enter a last date of attendance if the student failed to attend class; however, there is no written policy to rely which instructors are required to enter a last date of attendance.
Marymount University followed the University grading policy when determining whether or not a student received an earned F grade in all of his/her courses. (See below for policy information). Marymount University?s grading policy states that an F grade is assigned for students who fail to meet course objectives; such an F grade is by definition an earned F and not an unearned F as the student has completed the course but failed to meet standards. Marymount University instructors assign FA (Failure to Attend) grades for students who disappear, walk away, or otherwise fail to complete a course. For FA grades, last dates of attendance are assigned by instructors in the majority of cases. In the case of the students cited in the finding, Marymount followed its own grading policy when determining whether or not the failing grade received by the student was an earned F (completing the course but failing to meet course objectives) or an FA grade (failure to attend and did not complete the course). F grades would not result in Return to Title IV Funds calculations since they were considered earned. FA grades would result in Return to Title IV Funds calculations because they were considered unearned failing grades. Marymount University is not an attendance-taking institution according to Title IV standards, and individual instructors have control over their own attendance policies. Last dates of attendance as reported by these instructors are used in Return to Title IV Funds calculations; if a last date of attendance cannot be determined, the 50% point is used. Marymount University has the policy in place. However, Marymount University will review the language of the policy and revise the language to remove any ambiguities in the future. Marymount University Attendance Policy https://marymount.smartcatalogiq.com/en/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/attendance/ Undergraduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/evaluation-of-students/undergraduate-grading-policies/ Graduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/graduate-academic-information-and-policies/evaluation-of-students/graduate-grading-policies/
2021-005
Based on professional judgement, we selected six students for withdraw testing and five of the six students required a refund based on documented correspondence. Three of the five had incorrect R2T4 calculations. Cause: The first student?s institutional charges were incorrect on the R2T4 calculation. The second student?s direct loans were entered as aid that could have been disbursed, but there was not a promissory note signed by the student. A withdrawal date was used for the third student, however, the student never attended during the semester.
Show full finding ▾Hide full finding ▴Criteria: If an institution is not required to take attendance, the institution may use as the withdraw date, the date that the student began the withdrawal process as prescribed by the institution. Condition: Based on professional judgement, we selected six students for withdraw testing and five of the six students required a refund based on documented correspondence. Three of the five had incorrect R2T4 calculations. Cause: The first student?s institutional charges were incorrect on the R2T4 calculation. The second student?s direct loans were entered as aid that could have been disbursed, but there was not a promissory note signed by the student. A withdrawal date was used for the third student, however, the student never attended during the semester.
Marymount University administration acknowledges the findings from the 2021-2022 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2021-2022 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: - Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. - In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to assure compliance with Title IV regulations, including Return to Title IV Funds process. - Due to the turnover in the office, the calculations were not completed. Attain Partners has completed the reconstruction and COD updates. - Current R2T4 processes are in line with Title IV regulations. Attain Partners will assure timely processing going forward. - Attain Partners will be reviewing existing processes related to student financial aid. As an outcome of this review the processes and schedule will be fully documented and implemented as documented.
2021-003
FAC accepted this audit on February 9, 2023 — management decision was due August 9, 2023.
Institutions are required to reconcile all Direct Loan (DL) disbursements and submit required records to the Department of Education through the Common Origination and Disbursement (COD) system. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records (?DL reconciliations?). We requested DL reconciliations for the months of August 2020 and January 2021. The University could not provide completed DL reconciliations for these months
Show full finding ▾Hide full finding ▴Institutions are required to reconcile all Direct Loan (DL) disbursements and submit required records to the Department of Education through the Common Origination and Disbursement (COD) system. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records (?DL reconciliations?). We requested DL reconciliations for the months of August 2020 and January 2021. The University could not provide completed DL reconciliations for these months
Marymount University administration acknowledges the findings from the 2020-2021 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2020-2021 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: -Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover,including lack of continuity in office processes and lack of knowledgeable staff. -In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to ensure compliance with Title IV regulations, including Direct Loan reconciliation. -Attain Partners has fully reconciled the 2020-2021 Federal Direct Loan funds and has put processes in place in conjunction with the Marymount University Office of Financial Services to ensure timely monthly and final reconciliation going forward.
Institutions are required to submit disbursement records to the Department of Education?s Common Origination and Disbursement (COD) system, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. As part of our testing of Pell Grant disbursements, we tested the requirement to report payment data to COD within the 15 day requirement. Of the 24 total Pell recipients selected for testing, two students had disbursements that were not reported to COD.
Show full finding ▾Hide full finding ▴Institutions are required to submit disbursement records to the Department of Education?s Common Origination and Disbursement (COD) system, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. As part of our testing of Pell Grant disbursements, we tested the requirement to report payment data to COD within the 15 day requirement. Of the 24 total Pell recipients selected for testing, two students had disbursements that were not reported to COD.
Marymount University administration acknowledges the findings from the 2020-2021 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2020-2021 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: -Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover,including lack of continuity in office processes and lack of knowledgeable staff. -In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to ensure compliance with Title IV regulations, including the reporting of Federal Pell Grant verification status. -Attain Partners has fully reconciled the 2020-2021 Federal Pell Grant funds. In the process Attain Partners staff corrected verification status for V1 verification that were waived due to CARES act waiver provisions. -The University will continue with the current practice to report Pell disbursements within 15 days of disbursement, waive all V1 verifications where appropriate and correctly complete the status for others. The Office of Financial Aid in conjunction with the Office of Information Technology established an appropriate schedule and review process to ensure for timely system updates
If an institution is not required to take attendance, the institution may use as the withdraw date, the date that the student began the withdrawal process as prescribed by the institution. Based on professional judgement, we selected three students for withdraw testing and two of the three students required a refund based on correspondence received by the University from the students.
Show full finding ▾Hide full finding ▴If an institution is not required to take attendance, the institution may use as the withdraw date, the date that the student began the withdrawal process as prescribed by the institution. Based on professional judgement, we selected three students for withdraw testing and two of the three students required a refund based on correspondence received by the University from the students.
Marymount University administration acknowledges the findings from the 2020-2021 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2020-2021 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: -Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover,including lack of continuity in office processes and lack of knowledgeable staff. -In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to ensure compliance with Title IV regulations, including Return to Title IV Funds process. -COVID waiver provisions for R2T4 from the CARES Act allow schools to apply blanket waivers to all students during periods of disruption to course delivery and other institutional activities. Marymount University has chosen to apply this blanket waiver to all students who may need R2T4 calculations for the 2020-2021 year. Due to the turnover in the office, the calculations were not completed. Attain Partners is assisting with the reconstruction and COD updates. -Current R2T4 processes are in line with Title IV regulations. The Office of Financial Aid, with the support of Attain Partners, will ensure timely processing going forward.
When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student?s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Based on professional judgement, we selected three students for withdraw testing and two of the three students required a refund. The University calculated the return of funds for these students but failed to return required amounts to the Title IV programs.
Show full finding ▾Hide full finding ▴When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student?s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Based on professional judgement, we selected three students for withdraw testing and two of the three students required a refund. The University calculated the return of funds for these students but failed to return required amounts to the Title IV programs.
Marymount University administration acknowledges the findings from the 2020-2021 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2020-2021 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: -Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover,including lack of continuity in office processes and lack of knowledgeable staff. -In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to ensure compliance with Title IV regulations, including Return to Title IV Funds process. -COVID waiver provisions for R2T4 from the CARES Act allow schools to apply blanket waivers to all students during periods of disruption to course delivery and other institutional activities. Marymount University has chosen to apply this blanket waiver to all students who may need R2T4 calculations for the 2020-2021 year. Due to the turnover in the office, the calculations were not completed. Attain Partners is assisting with the reconstruction and COD updates. -Current R2T4 processes are in line with Title IV regulations. The Office of Financial Aid, with the support of Attain Partners, will ensure timely processing going forward.
A school must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Based on professional judgement, we selected four students who received all failing grades for testing and all students had at least one instructor document the student?s last date of attendance. Three of the four student?s documented last date of attendance was before the 60% point of the payment period, for which a refund would possibly be required if the student did not attend any class through the end of the period.
Show full finding ▾Hide full finding ▴A school must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Based on professional judgement, we selected four students who received all failing grades for testing and all students had at least one instructor document the student?s last date of attendance. Three of the four student?s documented last date of attendance was before the 60% point of the payment period, for which a refund would possibly be required if the student did not attend any class through the end of the period.
Marymount University administration acknowledges the findings from the 2020-2021 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2020-2021 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: -Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover,including lack of continuity in office processes and lack of knowledgeable staff. -In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to ensure compliance with Title IV regulations, including Return to Title IV Funds process.-COVID waiver provisions for R2T4 from the CARES Act allows schools to apply blanket waivers to all students during periods of disruption to course delivery and other institutional activities. Marymount University has chosen to apply this blanket waiver to all students who may need R2T4 calculations. Due to the turnover in the office, the calculations were not completed. Attain Partners is assisting with the reconstruction and COD updates. -Current R2T4 processes are in line with Title IV regulations. The Office of Financial Aid, with the support of Attain Partners will, ensure timely processing going forward. -Attain Partners has assisted Marymount University with detailed reports for students with all F grades to determine if any of the grades were earned or if a R2T4 calculation is needed. Attain will also support Marymount with the evaluation of the documented policy and procedures and ensure any appropriate updates are made to ensure continued timeliness and compliance.
A Single Audit requires the submission of the Date Collection Form (DCF) to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of an auditor?s report, or nine months after the end of the audit period, unless a different period is specified in a program-specific audit guide. The fiscal year 2020-2021 audit was not completed timely and the DCF was not submitted to the FAC within the required timeline.
Show full finding ▾Hide full finding ▴A Single Audit requires the submission of the Date Collection Form (DCF) to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of an auditor?s report, or nine months after the end of the audit period, unless a different period is specified in a program-specific audit guide. The fiscal year 2020-2021 audit was not completed timely and the DCF was not submitted to the FAC within the required timeline.
Marymount University administration acknowledges the findings from the 2020-2021 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2020-2021 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: -Marymount University has experienced a turnover in the financial services office as well as the financial aid from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. -In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. -The Attain Partners consultants have provided the interim management services to ensure compliance with Title IV regulations, and have partnered with the Financial Services team at Marymount to provide the appropriate responses and documentation to the external auditors in order to complete the FY 2020-2021 UG audit and submit it to the FAC in February 2023. -The University confirms that this finding resulted from one-time, extraordinary circumstances and further ensures that future audits will be completed and submitted in a timely manner.
FAC accepted this audit on October 20, 2022 — management decision was due April 20, 2023.
FAC accepted this audit on February 19, 2020 — management decision was due August 19, 2020.
FAC accepted this audit on March 17, 2019 — management decision was due September 17, 2019.
FAC accepted this audit on December 13, 2017 — management decision was due June 13, 2018.
FAC accepted this audit on March 14, 2017 — management decision was due September 14, 2017.
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