Queens University of CharlotteHigher 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 (Including Statutory, Regulatory or Other Citation): 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 Program via the National Student Loan Data System (the “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). 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. 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. Condition: Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 3 of 40 campus level records tested, the University did not certify the student’s change in enrollment status within the required timeframe. For 8 of 40 campus level records and 14 of 40 program level records tested, the University did not accurately report all enrollment data elements. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-001. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that enrollment data is timely and accurately reported to NSLDS. Views of Responsible Officials: There were three main problems with our enrollment reporting this year. We will also be providing detailed information from the National Student Clearinghouse’s audit team for the students flagged, and our corrective actions. 1. G following W statuses – this is a repeat issue from last year, but we had already done significant cleanup prior to this year’s audit. After last year’s finding, the Associate Registrar and Assistant Registrar – Degree Specialist reviewed our conferral process for students who have a later date of determination of degree completion. Records from 2024-2025 to present were corrected and uploaded to National Student Clearinghouse. However, these changes did not make it to NSLDS. Corrective Action: Student Financial Services and Registrar’s Office will review enrollment and graduation submissions on a monthly basis to ensure NSC and NSLDS are both being updated in a timely manner. 2. Students with enrollment prior to reported start term – there are two main reasons for this error: a. Student was in a placeholder “pre-bill” course at first-of-term enrollment, never fully enrolled in coursework and was dropped from the pre-bill course, and admissions later reported the student postponed to the next semester. Corrective Action: On the first day of the term, the registrar’s office will send the Admissions Team a list of students who have not yet fully enrolled in coursework and will ask for a status update. Any student who has not been in touch with Admissions or Academic Advising will be dropped from the placeholder course before first-of-term submission. Students who postpone enrollment after first-of-term submission will be corrected via Student Lookup functionality in National Student Clearinghouse. b. Student started coursework in summer but had a Fall start date. These students were basketball players who, per NCAA Division I rules, are allowed to start practicing with the team in the summer term as long as they are enrolled in courses. The past two summers, these students have typically committed to Queens and have been imported to Jenzabar prior to the registrar’s office even knowing that they are basketball players. Often these players arrive on campus and register in courses with very short notice to those outside of the basketball team. This short notice led to human error in updating their records. Corrective Action: The Registrar’s Office will work with Admissions, Enrollment Operations, Athletics, and Athletic Advising to develop a formal process of notification and onboarding for these students. 3. Program Begin Date errors – a. Historically we have had several majors that required admission so had two programs set up in Jenzabar with the same CIP code. At this time we only have one remaining program like this (nursing). Corrective Action: The Registrar’s Office will consult with National Student Clearinghouse staff to determine the best way to report these students. b. Jenzabar was capturing the date of major changes as the program effective date, which is not always accurate. Corrective Action: The Registrar’s Office will test a proposed process improvement in Jenzabar and will request Jenzabar consulting if needed. Additionally, two staff members will review downloaded warnings and errors from enrollment reports prior to final submission to NSC and will ensure Jenzabar is also correct to prevent recurring bad dates.

FINDING 2025-002 Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education (“ED”) no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)). Condition: Certain return of Title IV (“R2T4”) calculations were not accurately prepared and/or returns were not made within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: Return of funds was not properly calculated and returned. Questioned Costs: Below reportable threshold. Context: For 3 of 6 students tested, the unearned amount calculated was not returned within the required timeframe. For 2 of 6 students tested, the University did not accurately determine the amount to return. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-003. Recommendation: We recommend the University enhance its policies and procedures to ensure timely and accurate return of funds to ED. Views of Responsible Officials: The institution acknowledges the R2T4 calculation errors identified in the audit for the 2024–2025 award year. This finding is not consistent with prior-year R2T4 findings and has been determined to be the result of an isolated processing error by a former staff member who applied incorrect withdrawal dates when completing the Return of Title IV (R2T4) calculations. Specifically, for students enrolled in modular (term-based) coursework, the end date of the individual term was incorrectly used to perform the R2T4 calculation rather than the end date of the full semester/payment period. This resulted in inaccurate calculations of earned and unearned aid, and subsequently, an under-return of Title IV funds. The institution will take immediate corrective action and will return the outstanding funds identified through the campus systems and the COD system: • Student 1: $7,967 • Student 2: $799 To prevent this issue from recurring, the institution is implementing the following controls: • Enhanced Training: All financial aid staff responsible for R2T4 calculations will complete updated Federal Student Aid training on modular program requirements, with an emphasis on correctly identifying the payment period end date. • Secondary Review Process: All R2T4 calculations will undergo a secondary review by a team member either the Associate Director or Director, prior to finalization, to ensure accuracy and compliance. • System Controls and Checklists: A standardized checklist will be required for each R2T4 calculation to verify key data elements, including enrollment type and correct period end dates. This will also require the Secondary Reviewer to a place to acknowledge the R2T4 has been reviewed. o The Financial Aid Office staff will implement the use of the R2T4 module in the campus financial aid awarding system, PowerFaids, to add another level of controls, and can be closely monitored by upper-level staff members. o Moving the processing of the R2T4 to Powerfaids will also assist in the implementation of the Secondary Review Process, to create a streamlined process for processing, and review. • Ongoing Monitoring: The institution’s financial aid staff along with other campus partners including, student accounts, and the University registrar's office will conduct periodic internal audits of R2T4 calculations each term to ensure continued compliance and identify any ongoing issues that need to be addressed within the regulated timeline for the processing of R2T4.

FINDING 2025-003 Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Work-Study Program (ALN #84.033), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COA and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not properly calculate the student’s COA. For both students, we determined that there were no overawards of federal or nonfederal aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls to ensure that students are appropriately budgeted. Views of Responsible Officials: The institution acknowledges the Cost of Attendance (COA) discrepancies identified in the audit for the 2024–2025 award year. This finding is not consistent with prior-year findings and has been determined to be the result of documentation related to tracking student housing status changes. Specifically, two students selected for COA testing were assigned an “Off Campus” COA budget. While neither student exceeded their assigned COA, the institution was unable to provide documentation to support when the students’ housing status changed or when the institution became aware of the change. As noted during audit, the documentation was not maintained to provide evidence of the timing of these changes. In coordination with campus partners, it was confirmed that housing status updates were not formally documented, and as a result, Student Financial Services (SFS) did not update the students’ COA budgets. The institution has taken corrective action to address this gap and ensure appropriate documentation and alignment of student records moving forward. To prevent this issue from recurring, the institution is implementing the following controls: • Formal Reconciliation Process: A recurring reconciliation will be established between housing and SFS to verify student residential status and ensure COA budgets are accurate and up to date on the census date of each period of enrollment. • Standardized Documentation Procedures: Procedures have already been implemented requiring documentation of housing status changes, including when the institution becomes aware of the change. The housing office and the financial aid office will collaborate on ways to ingenerate into the university's main student information system to enhance internal controls. • Ongoing Monitoring: Periodic reviews will be conducted to confirm that student residency status and COA assignments remain aligned and properly documented. These measures are designed to strengthen internal controls, improve documentation, and ensure accurate and consistent administration of Cost of Attendance budgets in compliance with federal regulations.

FINDING 2025-004 Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations, 34 CFR 690.83, require the University to submit origination records for students to the Common Origination and Disbursement System (“COD”). Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Condition: For certain disbursements identified through our testing, errors were identified in key items reported to the COD in student origination records. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: For 5 of 25 origination records tested, the University did not accurately report all key items. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls over COD reporting to ensure origination record data is accurately reported. Views of Responsible Officials: The University acknowledges the finding related to inaccuracies in certain data elements reported within student origination records submitted to the Common Origination and Disbursement (COD) System. A review of the records identified that, in several cases, updates were required through maintenance files to correct Cost of Attendance (COA) data elements in COD. Additionally, one student record contained an academic year end date that was not aligned with the student’s enrollment reporting. While these discrepancies did not result in any instances of students exceeding their Cost of Attendance or receiving overawards, the University recognizes the importance of ensuring all data elements are accurately reported in compliance with federal regulations. The errors identified were the result of oversight regarding the submission of maintenance files. Corrective Actions: 1. Timely Submission of Maintenance Files: Procedures will be enhanced to ensure that any updates impacting student records, including changes to Cost of Attendance, are promptly submitted to COD via maintenance files. During the monthly reconciliation process that is already completed, procedures will be implemented for the proper processing of the maintenance files. This will enhance the internal controls for accuracy. 2. Staff review/training of Standardized Procedures: The Office of Student Financial Services will review the written procedures outlining the process for originating and updating records in COD. Make any necessary updates to ensure origination record data is reported. These procedures will clearly define responsibilities and include specific guidance on when maintenance updates are required. 3. Staff Training and Cross-Training: Staff involved in COD reporting will complete targeted training on federal requirements under CFR 690.83, with emphasis on maintaining accurate COA data and aligning academic year dates with enrollment reporting. Cross-training will be implemented to promote consistency and continuity. 4. Periodic Quality Control Reviews: A monthly sample review will be conducted on a sample of origination and maintenance records submitted to COD to ensure accuracy and completeness. Any discrepancies identified will be corrected promptly, and results will be used to enhance procedure improvements.

FINDING 2025-005 Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Credit Balances: Title IV regulations (34 CFR 668.164(h)) require institutions to pay Title IV credit balances directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: The University was not in compliance with federal regulations over the payment of Title IV credit balances to students. Questioned Costs: None. Context: For 1 of 25 Title IV credit balances tested, the University did not pay the student’s Title IV credit balance within the required timeframe. For 1 of 25 Title IV credit balances tested, the University held the student’s Title IV credit balance without the student’s authorization. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls to ensure that Title IV credit balances are paid to students timely. Views of Responsible Officials: The institution acknowledges the Credit Balance Refund violations identified in the audit for the 2024–2025 award year. This finding is not consistent with prior-year findings and has been determined to be the result of human error during review of weekly refund rosters. Specifically, one student selected for Credit Balance Refund testing had their refund inadvertently deleted from the weekly batch after disbursement but included in the following week’s batch. As a result, the refund was issued on the 15th day rather than within the required 14 days. The second student received only one loan disbursement for a term in which two courses were registered in different subterms. The net refund was processed within the 14 days but the loan amount retained for the second session course was not documented with written permission from the student. The institution has taken corrective action to address these categories of errors and ensure appropriate initiation and review of weekly student loan disbursement and refund processing. To prevent this issue from recurring, the institution is implementing the following controls: • Second Review of Refund Roster: A full review of each weekly refund roster will be performed by a second staff member in the department to ensure that all refunds specifically related to Title IV funds disbursement are initiated and completed within the required 14 days. • Documentation of Permission to Retain Funds for Subterm Registrations: A procedure will be implemented to ensure that in each weekly refund batch review any retention of a credit balance approved by a student for a subsequent approved charge is documented in writing and retained with the refund roster. These measures are designed to strengthen internal controls, improve documentation, and ensure accurate and consistent administration of Credit Balance Refunding in compliance with federal regulations.

FINDING 2024-001 Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 Program via the National Student Loan Data System (the “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). 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. 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. Condition: Certain students’ campus-level enrollment data was not accurately reported. Cause: In both instances, the graduate submission schedules were reported to the registrar timely. Subsequent to that date, both students were qualified to graduate, however, updated student statuses were not reported to the NSLDS. 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 students’ enrollment statuses were incorrectly reported as withdrawn instead of graduated. Identification as a Repeat Finding: There was no similar finding identified in the prior year. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that campus level enrollment data is timely and accurately reported to NSLDS. Views of Responsible Officials: Certain students’ campus level enrollment data was not accurately reported. The Registrar’s Office will determine why certain students falling outside of normal graduate submission schedules are not being captured in DegreeVerify files submitted to the National Student Clearinghouse. Manual submissions for these non-standard graduates will be performed until a reporting solution is identified.

FINDING 2024-002 Federal Program Information: Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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: The University was unable to provide evidence of loan disbursement notifications for certain students. Cause: Administrative oversight. Effect or Potential Effect: The University was unable to evidence compliance with loan notification requirements for those students. Questioned Costs: None. Context: For 8 of 25 disbursements tested, the University was unable to provide documentation showing that a notification was sent within the required timeframe to the borrower regarding the loan disbursement. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-002. Recommendation: We recommend the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers within the prescribed timeframe. Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the students in question; however, we can only document the loan disbursement notification was sent but are unable to document the date or content of the communication. Students identified with missing communications are from spring 2024. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement a loan disbursement notification to loan recipient reconciliation process to effectively capture students with missing communications to ensure that both a record of the notification and the date are maintained.

FINDING 2024-003 Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn (34 CFR section 668.173(b)). Condition: The University did not appropriately return the amount of unearned funds within the required timeframe. Cause: The University correctly determined the amount of Title IV aid earned for a student, but due to administrative oversight, erroneously processed the return of funds. Effect or Potential Effect: Returns of Title IV funds were not made within the required timeframe. Questioned Costs: None. Context: For 1 of 6 students tested, the amount calculated as due for return was not appropriately returned. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend the University enhance its procedures over return of Title IV funds to ensure unearned portions of federal aid are appropriately returned to the U.S. Department of Education. Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The University correctly determined the amount of Title IV aid earned for a student within the required timeframes, but due to administrative oversight, omitted one of the required awards from the return update on the student account. A regular review of R2T4 calculations will be developed to ensure that the actual returns match the return calculations.

Federal Program Information: Federal Work-Study Program (ALN 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 U.S. Department of Education (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 was identified where funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with Cash Management requirements. Questioned Costs: None. Context: An early draw of the University’s 21-22 award year carry-forward resulted in excess cash that was not eliminated timely. Identification as a Repeat Finding: There was no similar finding identified in the prior year. Recommendation: We recommend the University enhance its procedures to ensure that excess cash is returned timely. Views of Responsible Officials: Cash management of Title IV funds at the University is generally performed only on a reimbursement basis. In this situation there was a one-time error in calculating available FWS funds and year-to-date FWS earnings such that approximately $11,000 in excess cash was received near the end of the 21-22 year and then carried forward. The error was discovered early in 22-23 but by that point earnings had outpaced cash on hand and so no effort was made to return funds. A new procedure with a multi-year workbook has been established for monitoring FWS earnings across award periods to prevent a repeat occurrence.

Federal Program Information: Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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: Records showing that a loan disbursement notification was sent were not retained for a certain student. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with loan notification requirements. Questioned Costs: None. Context: For 1 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: No similar finding identified in the prior year. Recommendation: We recommend the University enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers. Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for both the fall 2022 and spring 2023 semesters. We can document the spring 2023 loan disbursement notification was sent but are unable to document the date. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement additional controls to effectively capture a student’s disbursement notification to ensure that both a record of the notification and the date are maintained.

Federal Program Information: Student Financial Assistance Cluster (Various ALN’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: A transfer student was not added to the Transfer Monitoring List. Cause: Administrative oversight. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003. Recommendation: We recommend the University enhance its procedures to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.

Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn. Condition: Students’ return calculations were not accurately prepared due to improper inclusion of institutionally scheduled breaks. Cause: Administrative oversight and insufficient internal controls. Effect or Potential Effect: Over or underpayment of Title IV funds. Questioned Costs: None. Context: For 2 of 4 students tested, the amounts to return were not calculated in accordance with the requirements. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend the University enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined. Views of Responsible Officials: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods.

Federal Program Information: Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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). 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. 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. 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. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Certain students’ program-level enrollment data was not accurately reported. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 5 of 40 program level records tested, the students’ program begin date was not accurately reported. Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-001. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure that program-level enrollment data is timely and accurately reported to NSLDS. Views of Responsible Officials: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly.

FINDING 2022-001 Federal Program Information: Federal Pell Grant Program (CFDA #84.063) and Federal Direct Student Loans (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students? statuses on the National Student Loans Data System (NSLDS) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. 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. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Cause: Administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 3 of 27 Campus-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 3 of 27 Program-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 5 of 27 Program-Level Records sampled, the University did not accurately report all significant data elements in a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Two students were not included in the conferral file that was transmitted to the National Student Clearinghouse. For 3 of 27 Campus-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 3 of 27 Program-Level Records sampled, the University did not report the student?s change in status in a timely notification to the NSLDS website. For 5 of 27 Program-Level Records sampled, the University did not accurately report all significant data elements in a timely notification to the NSLDS website. While NSC records were reviewed, these items were not caught. Moving forward, two staff members will review each record to ensure that the graduated status is reported correctly. We will work with Student Financial Services to determine if there is a NSLDS report that can be pulled and reviewed after each conferral cycle. Program level data was reported to the NSC. We will work with the NSC to determine why all records aren?t being reported to the NSLDS.

FINDING 2022-002 Federal Program Information: COVID-19 Education Stabilization Fund (?ESF?) - Student Aid Portion (CFDA 84.425E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? Quarterly Public Reporting ? The University is required to publicly post certain information for the Student Aid Portion award on the University?s website in a conspicuous location. Institutions must post certain key line items identified by the ED as critical information directly to their website each calendar quarter, and reports must be updated no later than 10 days after the end of each calendar quarter. Condition: Certain key line items were not correctly reported in the University?s quarterly reports. Cause: Administrative oversight with respect to quarterly public reporting requirements. Effect or Potential Effect: The University is not in compliance with reporting requirements. Questioned Costs: None. Context: For 2 of 2 quarters selected for testing, certain required key line items for the Student Aid Portion awards reported on the University?s website contained inaccurate information. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend the University enhance its policies and procedures over quarterly reporting to ensure that all required information is reported accurately, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: Queens? quarterly reports were updated and submitted with all corresponding and accurate disbursements appropriately noted, but the University did not include quarterly disbursements and cumulative disbursements in the reports. All prior and future reports will be updated to make the distinction between funds disbursed in that quarter and total disbursed.

FINDING 2022-003 Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: A transfer student was not added to the Transfer Monitoring List. Cause: Administrative oversight. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 1 of 5 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials and Planned Corrective Actions: Admission data for one student was misclassified as an entering freshman when student was a transfer student. We have identified the source of the issue and taken the appropriate steps to correct on both the Admissions and Financial Aid sides going forward.

FINDING 2022-004 Federal Program Information: Federal Pell Grant Program (CFDA #84.063) and Federal Direct Student Loans (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Enrollment Reporting ?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. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgment file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Error records were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University is not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: Population of errors identified in Error/Acknowledgement files included 3 errors that repeated and were thus not corrected within the required 10-day timeframe. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend that the University enhance its policies and procedures over enrollment reporting to ensure that all errors are corrected within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: The Registrar?s Office will add an additional staff person to assist in reviewing and updating any error files that are received through the Clearinghouse site.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 did not match the underlying supporting documentation. Cause: Administrative oversight with respect to verification requirements. Effect or Potential Effect: The University is not in compliance with the required federal guidelines over verification. Questioned Costs: None. Context: For 4 of 25 students selected for verification testing, the University did not perform adequate verification procedures. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend that the University enhance its review procedures to ensure that information from Federal Student Aid Applications is properly verified and supported. Views of Responsible Officials and Planned Corrective Actions: Beginning with the 2021-2022 academic year Queens University has retained the services of a third-party provider, Inceptia, to complete the required verification function. For the four students identified as part of the verification findings, three of the errors resulted in no change in student eligibility and one resulted in an aid underpayment.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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. Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education (?ED?) 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 section 668.173(b)). If a student does not begin attendance in a payment period or period of enrollment, the institution must return all Title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for that payment period or period of enrollment. The institution must return those funds for which it is responsible under to the respective Title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance (34 CFR section 668.21). If the total amount of Title IV grant or loan assistance, or both, that the student earned is greater than the total amount of Title IV grant or loan assistance, or both, that was disbursed to the student of on behalf of the student in the case of a PLUS loan, as of the date of the institution?s determination that the student withdrew, the difference between these amounts must be treated as a post-withdrawal disbursement. If outstanding charges exist on the student?s account, the institution may credit the student?s account up to the amount of outstanding charges with all or any portion of loan funds that make up the post-withdrawal disbursement in accordance with 34 CFR sections 668.164(d)(1), (d)(2), and (d)(3) only after obtaining confirmation from the student or parent in the case of a PLUS loan, that they still wish to have the loan funds disbursed to their account (34 CFR sections 668.22(a)(5) and (a)(6)(ii)(A)). Condition:The University improperly prepared the refund calculations for certain students selected for testing. Additionally, the University did not return funds to the ED within the required time frame for certain students selected for testing. Cause: Insufficient administrative oversight resulted in inaccurate withdrawal calculations being prepared and refunds not being returned within the required timeframe. Effect or Potential Effect: The University is not in compliance with the required federal guidelines over the return of Title IV funds. Questioned Costs: Below reporting threshold. Context: For 2 of 9 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. Additionally, for 1 of 9 students selected for testing, funds were not returned to the ED within the required timeframe. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend that the University enhance its policies and procedures to ensure that withdrawal calculations are properly prepared and that refunds are returned within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Due to human error, total institutional charges were incorrectly entered for one student resulting in an overstated return of funds. For the other student, we have identified process improvements due to this finding. A calculation was not performed, and funds were not returned for one student that was reported as receiving all Fs for the semester in question. Student Financial Services (SFS) previously relied on Registrar data and responses to determine the last dates of attendance for students in this circumstance. SFS can now obtain the last dates of attendance, when reported, using existing software functionality. We believe this will capture the data more accurately for R2T4 purposes. In addition, the R2T4 function was re-assigned to other staff beginning with the 2021-22 academic year.

Federal Program Information:Federal Pell Grant Program (CFDA #84.063) and Federal Direct Student Loans (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. 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. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Cause: Administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Campus-Level Record in a timely notification to the NSLDS website. For 1 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: One student was not included in the May 2021 conferral materials that were transmitted in May 2021. Moving forward, all undergraduate students who have earned 120.0 or more credits will be reviewed to ensure that the appropriate status is reported to the National Student Clearinghouse. The other student identified was scheduled to attend in the Fall 2020 semester. Due to COVID, he delayed his enrollment at Queens to Spring 2021. The change in effective date at the program level was not adjusted to the January start. The Registrar?s Office will review all incoming student records at the program level to ensure that all dates are in alignment.

Federal Program Information: COVID-19 Education Stabilization Fund (?ESF?) - Student Aid Portion (CFDA 84.425E) and Institutional Portion (CFDA 84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? Quarterly Public Reporting ? The University is required to publicly post completed quarterly reporting forms for the Institutional Portion award and certain information for the Student Aid Portion award on the University?s website in a conspicuous location. For the Institutional Portion award, a new, separate form covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds must be posted each quarterly reporting period. Institutions must post this quarterly form no later than 10 days after the end of each calendar quarter. For the Student Aid Portion award, Institutions must post certain key line items identified by the ED as critical information directly to their website each calendar quarter, and reports must be updated no later than 10 days after the end of each calendar quarter. Condition: The University did not post required quarterly reporting information to the University website within the required time frames. Cause: Administrative oversight with respect to quarterly public reporting requirements. Effect or Potential Effect: The University is not in compliance with reporting requirements. Questioned Costs: None. Context: For 2 of 2 quarters selected for testing, the University did not post the required Institutional Portion award quarterly forms or the required key line items for the Student Aid Portion award to the University?s website within 10 days of each respective quarter?s end. Identification as a Repeat Finding: No similar finding identified in the prior year. Recommendation: We recommend that the University enhance its policies and procedures over quarterly reporting to ensure that all quarterly reports and required information is updated and posted to the University?s website within the required time frame. Views of Responsible Officials and Planned Corrective Actions: HEERF reporting is a new requirement for 2020-21 initiated due to the various rounds of Covid relief aid. Queens? quarterly reports were updated and submitted with all corresponding and accurate disbursements appropriately noted, but the University did not maintain support to prove whether the reports were updated on the website within the required timeframe. All relevant documentation from the Department of Ed has been reviewed to ensure timely quarterly and annual reporting for funds disbursed in the 2021-2022 academic year.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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 a student selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight with respect to verification requirements. Effect or Potential Effect: The University is not in compliance with the required federal guidelines over verification. Questioned Costs: Below reporting threshold. Context: For 1 of 25 students selected for verification testing, the University did not perform adequate verification procedures. Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend that the University enhance its review procedures to ensure that information from Federal Student Aid Applications is properly verified and supported. Views of Responsible Officials and Planned Corrective Actions: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation. The University?s newly hired Financial Aid Director has already reviewed the error with the staff member responsible to ensure understanding and will institute a process of internal audit sampling to ensure staff are fully conversant with the verification regulations, and also to monitor human errors for only necessary corrective actions to ensure verification compliance going forward.

Federal Program Information: Federal Direct Student Loans Program (CFDA#: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification: 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. Condition: For certain parent borrowers, the University did not notify the parent borrowers of the loan disbursement in a timely manner. Cause: Administrative oversight with respect to loan disbursement notification requirements. Effect or Potential Effect: Parents were not notified timely of award disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 2 of 25 students selected for testing, parent borrowers did not receive disbursement notifications within the required time frame. Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend that the University properly follow its policies and procedures over disbursement notifications to ensure that notifications are sent to parent borrowers within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: A new staff member failed to populate a field required to trigger the generation of the disbursement notification to the parent borrower. The procedure was reviewed with all staff members that award parent loans to refresh the knowledge base. This error was self-discovered by the University and the Assistant Director responsible for disbursement processing introduced a new internal audit practice of reconciling number of loans disbursed to the number of notifications sent to eliminate the error in the future.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for certain students who graduated or withdrew during the year. Cause: Administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 25 students sampled whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: A review of this finding indicated a technical issue in the transmission of a degree file to the NSC. The student status flag was not set to `G? but left the student in `W? status. The University instituted a practice of review of `G? flags for the degree files to ensure the correct status was communicated from NSC to NSLDS.

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