Southern Virginia UniversityHigher Education

FINDING 2025-001 Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within the required timeframe. For 2 of 40 campus level records tested, the University did not notify the NSLDS of a change in the student’s enrollment. For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within the required timeframe. For 40 of 40 program level records tested, the University did not accurately report one or more significant data elements to the NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-001. Recommendation: We recommend the University enhances its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS.   Views of Responsible Officials: Audit testing identified errors in withdrawal effective dates, enrollment status changes, and program begin dates. Incorrect or untimely information was reported to NSLDS due to inconsistent internal communication and a lack of systematic reconciliation with National Student Clearinghouse (the “NSC”) reporting files. To ensure ongoing accuracy in enrollment reporting, Southern Virginia University is strengthening communication and coordination across departments involved in the reporting process. Beginning February 2026, the Financial Aid Office implemented a workflow to review NSC and NSLDS error reports more promptly and resolve discrepancies as they arise. Financial Aid will monitor this process monthly until errors are no longer identified, ensuring timely and accurate reporting going forward. The Registrar's Office will receive training on date reporting requirements and expectations for NSLDS so that they use the correct enrollment change dates.

FINDING 2025-002 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Notification of Disbursements - The institution must provide notification to the student of the amount of and type of Title IV funds they are expected to receive and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. Condition: For certain students selected for testing, evidence of award letters being sent to the student could not be provided, or the award letter was not sent timely. For certain students selected for testing, evidence of a disbursement notification being sent to the student or parent could not be provided, or the notification was not sent timely. Cause: Insufficient internal control and administrative oversight. Additionally, the system automated notification function was inadvertently turned off, requiring all notifications during the year to be processed manually. Effect or Potential Effect: The University was not in compliance with the requirements for notifying students or parents of the awards they could expect to receive, or the disbursement of federal loan funds to their account. Questioned Costs: None. Context: For 2 of 25 students tested, the University was unable to provide documentation supporting award letters being sent to the student. For 1 of 25 students tested, the University did not provide the student with an award letter until subsequent to the disbursement of funds. For 20 of 25 students tested, the University was unable to provide documentation supporting appropriate loan disbursement notification to students and/or parents. For 3 of 25 students tested, the loan disbursement notifications were not made within the required timeframe. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhances its internal controls over compliance to ensure that students or parents are appropriately notified of awards and disbursements as required. Views of Responsible Officials: A sample review identified documentation gaps in Award Letters and Loan Disbursement Notifications. Notification processes were manual, leading to inconsistent documentation in the financial aid management system during employment transitions that occurred during the award year. In October 2025, Southern Virginia University transitioned both award letter notifications and loan disbursement notifications to an automated process through the Student Financial Aid Management System. All notifications are now system-generated and automatically logged within each student’s record, ensuring a complete and permanent communication history. The Financial Aid Office will maintain automated notification workflows and conduct an annual review before each aid year to verify that award letter and loan disbursement notifications are generating automatically, and documentation of the notifications is happening correctly.

FINDING 2025-003 Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Return of Title IV Funds: 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 (34 CFR 668.22(e)(2)). 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. 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 (34 CFR 668.22(e)). Returns of Title IV funds must be distributed in the prescribed order (34 CFR 668.22(i)). Post-withdrawal disbursements of loan funds may be credited to the student’s account if current-year outstanding charges exist on the student’s account, up to the amount of the current-year outstanding charges only after obtaining confirmation from the student, or parent in the case of a parent PLUS loan, that he or she still wishes to have some or all of the loan funds disbursed 34 CFR 668.22(a)(6)). Condition: For a certain student that withdrew during the year, the University did not properly calculate the amounts to be returned to the ED. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Known questioned costs: $883; total questioned costs: $22,813. Known questioned costs of $883 were identified as a result of the described error in a withdrawal calculation; total questioned costs includes an error extrapolation over the entire population sampled. Subsequent to the identification of this error, the University returned the appropriate amount to the Department. Context: For 1 of 3 students tested, the University did not appropriately return the required amount of Title IV aid to the Department. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhances its internal controls and policies and procedures over the applicable compliance requirements to ensure that student withdrawal calculations are prepared accurately. Views of Responsible Officials: The University relied on a paper-based withdrawal process that did not consistently reach all departments in a timely manner. As a result, withdrawal dates and status changes were not always communicated accurately or in a timely manner between campus departments. Southern Virginia University has taken the following steps to resolve the issue: • A new internal check was created to verify that withdrawal dates match the verified withdrawal date before federal aid or institutional charges are updated. • The withdrawal form is being updated to require Financial Aid and Student Accounts signatures, ensuring that all relevant offices receive the information before it is finalized. • Communication procedures between the Registrar, Financial Aid, and Student Accounts have been formalized to ensure that withdrawal information is shared consistently. Southern Virginia University has also taken the following preventive actions: • A regular withdrawal review will be completed to confirm accurate dates, status changes, and timely updates across all departments and systems. • The University will maintain and distribute an updated written withdrawal workflow to impacted departments clarifying communication, verification, and documentation requirements for university withdrawals. • Staff in all involved departments will participate in training to reinforce the updated procedures.

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. 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. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 5 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. For 5 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment. For 25 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. See “Status of Finding” for Finding 2023-002.

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal controls over verification requirements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 8 of 15 students tested, the University did not complete appropriate verification procedures prior to disbursing aid. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required. Views of Responsible Officials: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process. 3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign. 3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal. 2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members.

Federal Program Information: Federal Direct Loan Program (ALN 84.268) Criteria or Specific Requirement: According to 34 CFR 685.303, except in the case of a late disbursement under 685.303(f) or as provided in paragraph (b)(3)(iii) of § 685.303, a school may disburse loan proceeds only to a student, or a parent in the case of a Direct PLUS Loan obtained by a parent borrower, if the school determines the student has continuously maintained eligibility in accordance with the provisions of § 685.200 from the beginning of the loan period for which the loan was intended. Condition: The University disbursed loan funds to a student who failed to make satisfactory academic progress at the end of his probationary period. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Overpayment of Title IV funds. Questioned Costs: Below reporting threshold. Context: For 1 of 40 students tested, the University did not appropriately assess the student’s eligibility prior to disbursing loan funds. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its internal controls over compliance to ensure proper determination of continuous eligibility. Views of Responsible Officials: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school.

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN 84.007) Criteria or Specific Requirement: C. Cash Management: Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the ED (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: An instance during the year was identified where funds drawn in excess of amounts disbursed were held longer than the allowable timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with cash management requirements. Questioned Costs: None. Context: 1 instance of cash held in excess of the allowable timeframe for the Federal Supplement Educational Opportunity Grants Program. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures to ensure excess cash balances are eliminated timely. Views of Responsible Officials: Corrective action steps have been taken to ensure that excess cash balances are eliminated in a timely manner. The corrective action focuses on the campus-based awards, as there was only one instance of non-compliance for the FSEOG, and adds an additional step between financial aid and the finance office to verify the amount of funds disbursed to students before initiating a drawdown of funds.

Federal Program Information: Federal Pell Grant Program (ALN 84.063) Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 2 of 40 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendar days. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-001. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD. Views of Responsible Officials: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid processing system, Jenzabar Financial Aid, which will simplify the process and prevent reporting delays.

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time(F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. 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. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 19 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days. For 1 of 40 campus level records tested, the University did not notify the Department of a change in the student’s enrollment. For 24 of 40 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment information via the National Student Clearinghouse (NSC) which will facilitate more timely reporting of future enrollment status changes to NSLDS and reporting of all significant data elements to NSLDS. Reporting to NSC by the University Registrar’s Office has begun.

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work- Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268) Criteria or Specific Requirement: Special Tests and Provisions – Return of Title IV Funds - 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. Condition: The University did not prepare a certain student’s return calculation properly. Cause: Administrative oversight. Effect or Potential Effect: Over or underpayment of Title IV funds. Questioned Costs: Below reporting threshold. Context: For 1 of 4 students tested, the University did not accurately determine both the calendar days completed and the period of enrollment when calculating the percentage of Title IV aid earned. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures over the preparation and review of R2T4 calculations to ensure compliance with the return of Title IV funds requirements. Views of Responsible Officials: An incorrect date was used to process one student’s Return ofTitle IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a report is being run several times a month to identify possible data entry errors in R2T4 calculations.

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: L. Reporting ? Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the ?ED?) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: Certain student disbursements were not reported to COD within 15 calendar days as required; certain disbursement records did not reflect the actual disbursement date. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the COD reporting requirements. Questioned Costs: None. Context: For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendars days. For 1 of 25 Pell disbursement records tested, the actual disbursement date was not accurately reported to COD. For 1 of 25 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days. For 1 of 25 Direct Loan disbursement records tested, the actual disbursement date was not accurately reported to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD. Views of Responsible Officials: Corrective action was taken. The University has since transitioned to a new Financial Aid processing system, Jenzabar Financial Aid (JFA), that automatically sends updates daily, making regular uploads of files to COD much simpler.

Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 5 of 9 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004. Recommendation: We recommend the University enhance its procedures and internal controls over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: Corrective action was taken. While verification was completed properly for each selected student, when changes were not required to the ISIRs of the students, ISIRs were not consistently released to COD. Now that the University is fully operating with its new financial aid system, JFA, we are running a daily process sending up ISIR corrections to COD for all students. Thorough review and training sessions on the verification process have been held with the financial aid team and we will continue to diligently monitor the verification process, including obtaining necessary documentation from students selected for verification and processing ISIR corrections.

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. 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. Condition: Campus Level: Certain students? enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the student?s enrollment data within 60 days. For 9 of 40 campus level records tested, the University did not notify the Department of the students? enrollment changes. For 12 of 40 campus level records tested, the University did not accurately report the students? enrollment effective dates. For 18 of 25 program level records tested, the University did not accurately report one or more significant data elements to NSLDS. 1 of 6 Enrollment Reporting roster files received during the year was not completed and returned within 15 days. Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-002. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students? enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Corrective action was taken. The financial aid team is working in tandem with the Registrar?s Office and the IT department to report enrollment information via the National Student Clearinghouse (NSC). This will be up and running by June 2023, enabling timely reporting of future enrollment status changes to NSLDS.

Federal Program Information: Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Test and Provisions ? Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Loan notifications do not appear to have been sent to certain borrowers. Additionally, certain borrowers received inaccurate notifications. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with loan notification requirements. Questioned Costs: None. Context: For 4 of 25 loan disbursement notifications tested, the University did not accurately notify the borrower of the disbursement date, amount, or Direct Loan type. For 2 of 25 Direct Loan disbursements tested, the University was unable to provide documentation showing that a notification was sent to the borrower. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers. Views of Responsible Officials: Corrective action was taken. The financial aid team has automated the loan disbursement notification email in JFA to ensure students are notified regarding their loan disbursement amounts, dates, etc. Periodic checks are being done to ensure that the notifications are functioning as expected.

Finding 2021-002: Enrollment Reporting Process U.S. Department of Education Student Financial Assistance Cluster Other Matters Compliance/Material Weakness Criteria or specific requirement: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a chance in a student?s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days. Condition: The University does not have a policy in place that would ensure timely reporting of student status changes to the NSLDS. Cause: Lack of oversight in ensuring student status changes are reported timely. Effect: The University is not in compliance with the enrollment reporting requirements. Questioned costs: None. Context: The University did not report student status changes to the NSLDS within the required 60-day time period for 36 of the 40 students selected for testing. Repeat finding: No Recommendation: The University should implement a policy to ensure it follows the Enrollment Reporting requirements. Views of responsible official: Management agrees with the finding. Refer to the University?s Corrective Action Plan.

Finding 2021-003: Higher Education Emergency Relief Fund Allocation U.S. Department of Education Student Financial Assistance Cluster Other Matters Compliance/Material Weakness Criteria or specific requirement: Higher Education Emergency Relief Funds II must be used to provide financial aid grants to students (including students exclusively enrolled in distance education), which may be used for "any component of the student's cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, healthcare (including mental health care) or child care. Additionally, schools must prioritize students with exceptional need, such as students who receive Pell grants. Condition: The University elected an allocation methodology that was not in line with Department of Education suggestions. Cause: The University elected to disburse HEERF II funds to students with an outstanding balance on account as of the end of the Spring semester. Effect: The University reassessed the students who received HEERF II funds to determine if the recipients were either Pell eligible or had an Expected Financial Contribution of $25,000 or less. Questioned costs: None Context: Based on the reassessment performed by management, there are no questioned costs and HEERF II was primarily disbursed to students who demonstrated exceptional need. Repeat finding: No Recommendation: We recommend that the University implement adequate procedures to ensure all eligibility requirements are considered and appropriately met prior to disbursement of funds. Views of responsible official: Management agrees with the finding. Refer to the University?s Corrective Action Plan.

Finding 2021-004: Incomplete Verification Process U.S. Department of Education Student Financial Assistance Cluster Other Matters Compliance Criteria or specific requirement: Federal regulations (34 CFR 668.59) require educational institutions to have policies and procedures in place to verify information in student financial aid applications. Condition: The verification process for the file of one student was not completed. Cause: The lack of a process to ensure that verification procedures for students identified for verification are completed and that any necessary updates or changes to student information are made. Effect: Student's records were not obtained to complete the verification process. Questioned costs: None. Context: We selected 40 students which had been identified as needing verification. For one of the selected students, the verification process was not completed. Repeat finding: Yes. See Finding 2020-002 Recommendation: The University should implement a process to ensure that verification procedures for identified students are completed and that any necessary updates or changes to student information are made. Views of responsible official: Management agrees with the finding. Refer to the University?s Corrective Action Plan.

Finding 2021-005: Return of Title IV Funds U.S. Department of Education Student Financial Assistance Cluster Other Matters Compliance Criteria or specific requirement: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED or the appropriate FFEL lender as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. (34 CFR 668.173(b)) Condition: The University did not return Title IV funds for one student within the 45-day requirement and incorrectly calculated the refund. Cause: Lack of administrative oversight in refunding Title IV funds. Effect: Return of this student's Title IV funds was not completed timely and was calculated and returned incorrectly. Questioned costs: This student was under-refunded $397 in subsidized loans. This value represents 2% of our sample. When extrapolated to the entire sample population, the total estimated, possible questioned costs are $5,745. Context: Based on a sample of 6 students who withdrew during the award year, a refund for one of the selected students was not returned within the 45-day requirement and was made for the incorrect amount. Repeat finding: Yes. See Finding 2020-003. Recommendation: We recommend that the University implement adequate procedures to ensure that all refunds of Title IV funds are returned within a timely manner and in the correct amount. Views of responsible official: Management agrees with the finding. Refer to the University?s Corrective Action Plan.

Item 2020-002: Verification U.S. Department of Education Student Financial Assistance Cluster Criteria or specific requirement: The U.S. Department of Education requires educational institutions to have policies and procedures in place to verify information in student financial aid applications. Condition: The verification process for the files of certain students was not completed. Cause: The lack of a process to ensure that verification procedures for students, identified for verification, are completed and that any necessary updates or changes to student information is made. Effect: Students? records were not correctly updated or changed appropriately. Questioned costs: None. Context: We selected 40 students which had been identified as needing verification. For nine of the selected students, the verification process was not completed. Repeat finding: No Recommendation: The University should implement a process to ensure that verification procedures for identified students are completed and that any necessary updates or changes to student information are made.

Item 2020-003: Refunding Unearned Federal Student Financial Aid U.S. Department of Education Student Financial Assistance Cluster Criteria or specific requirement: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED or the appropriate FFEL lender as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition: The University did not return Title IV funds for one student within the 45 day requirement. The University incorrectly calculated the refund for another student. Cause: Administrative oversight in refunding Title IV funds. Effect: Return of one student?s Title IV funds was not completed timely and for another student was calculated and returned incorrectly. Questioned costs: One student was over refunded $486 in Pell grants. No questioned costs for the student whose refund was not completed within the required timeframe. Context: Based on a sample of twenty students who withdrew during the award year, a refund for one of the selected students was not returned within the 45 day requirement and for another selected student was made in an incorrect amount. Repeat finding: No Recommendation: We recommend that the University implement adequate procedures to ensure that all refunds of Title IV funds are returned within a timely manner and in the correct amount. Views of responsible official: Refer to the University?s Corrective Action Plan.

Item 2020-004: Graham-Leach-Bliley-Act U.S. Department of Education Student Financial Assistance Cluster Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. 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 CFR313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the 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. Condition: The University does not have a policy in place documenting specific risks identified in relation to the Gramm-Leach-Bliley-Act or safeguards to address identified risks, nor has a documented risk assessment been performed. Cause: Oversight in recording formal documentation of (i) risks identified and (ii) safeguards to such risks. Effect: The University is not in compliance with the requirement to follow the Gramm-Leach-Bliley Act Questioned costs: None. Context: The University does not have in place the required formal documentation. Repeat finding: No Recommendation: The University should implement a policy to ensure it follows the Gramm-Leach-Bliley Act requirements. Views of responsible official: Refer to the University?s Corrective Action Plan.