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COLUMBIA INTERNATIONAL UNIVERSITY AND SUBSIDIARIESHigher Education

EIN: 570352247

UEI: MAKYDTN5CLM8

Audited by: CapinCrouse LLC

Oversight agency: 84 [Department of Education]

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Data as of August 28, 2026

COLUMBIA INTERNATIONAL UNIVERSITY AND SUBSIDIARIES10 audit years7 findings2 repeat
10
Audit Years
7
Total Findings
2
Repeat Findings
$13.7M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$13,723,036 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 2, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 2, 2026 (3 days from today).

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FY 2024-06-30

$13,503,485 federal awards expended

FAC accepted this audit on January 6, 2025 — management decision was due July 6, 2025.

2024-002
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2023-002QUESTIONED COSTSOTHER MATTERS

When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $134 Context: Out of 20 students tested, 4 students had late returns of $3,784 in Federal Direct Loans (FDL) and $2,777 in Pell ranging from 6 to 23 days late. Additionally, 6 students had incorrect R2T4 calculations. One student had an incorrect last date of attendance (LDA) used in the calculation causing an under-award of Pell ($55) in the student’s post-withdrawal disbursement (PWD). Four students had incorrect end dates used in their calculations, however it only impacted two students causing over-returns of Pell ($19). One student had incorrect total days in the payment period used in the calculation causing an under-return of federal direct loans ($134). These were corrected during the audit. Cause: There was turnover in the role of Associate Director for Online Studies midway through the academic year. Effect: Return of Title IV funds were not performed accurately and timely. Identification as repeat finding, if applicable: 2023-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend the University review calendar set-ups used for R2T4 calculations. Lastly, we recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Full finding narrative

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $134 Context: Out of 20 students tested, 4 students had late returns of $3,784 in Federal Direct Loans (FDL) and $2,777 in Pell ranging from 6 to 23 days late. Additionally, 6 students had incorrect R2T4 calculations. One student had an incorrect last date of attendance (LDA) used in the calculation causing an under-award of Pell ($55) in the student’s post-withdrawal disbursement (PWD). Four students had incorrect end dates used in their calculations, however it only impacted two students causing over-returns of Pell ($19). One student had incorrect total days in the payment period used in the calculation causing an under-return of federal direct loans ($134). These were corrected during the audit. Cause: There was turnover in the role of Associate Director for Online Studies midway through the academic year. Effect: Return of Title IV funds were not performed accurately and timely. Identification as repeat finding, if applicable: 2023-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend the University review calendar set-ups used for R2T4 calculations. Lastly, we recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Management agrees with the finding. The Registrar’s Office and the Financial Aid Office met on 12/17/24 to discuss the discrepancy between withdrawal dates used by Fin Aid and those used by the Registrar’s Office. It was agreed that LDA and withdrawal date should be the same date for students who officially withdraw and students that are dropped due to non-participation. It was agreed that the Registrar Office would notify the Financial Aid Office of students who are administratively dropped for non-participation in a timely manner. We also agreed that we should meet at least quarterly to review our procedures and communication between offices. The Associate Director and the Director will both review the calendar set-up dates used for R2T4 calculations in our POEs to insure the correct term dates are entered. The Associate Director has now moved her undergrad online caseload to another counselor so that she has more time to focus on her primary roles of processing R2T4s and disbursing aid. Person Responsible for Corrective Action Plan: Elizabeth Haselden, Registrar; Joy Brown, Degree Audit and Data Specialist; Laura McCall and Martha Lewis, Fin Aid Associate Directors; Patty Hix, Fin Aid Director Anticipated Date of Completion: May 31, 2025

Prior Finding References

2023-002

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2024-003
Special Tests & Provisions
MATERIAL WEAKNESSOTHER MATTERS

Students’ reported enrollment statuses were not always updated accurately and timely to NSLDS. Criteria: 34 CFR 690.83(b)(2), 34 CFR 685.309 Questioned Costs: $0 Context: 11 out of 75 students tested had reporting errors for NSLDS enrollment. These were corrected during the audit. Cause: Turnover in the Registrar’s office and system issues caused by transitioning online undergraduate students from non-standard terms to traditional terms. Effect: Delays and errors in enrollment reporting to NSLDS. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a spot check for NSLDS enrollment reporting periodically during the academic year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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NSLDS Reporting Errors Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Students’ reported enrollment statuses were not always updated accurately and timely to NSLDS. Criteria: 34 CFR 690.83(b)(2), 34 CFR 685.309 Questioned Costs: $0 Context: 11 out of 75 students tested had reporting errors for NSLDS enrollment. These were corrected during the audit. Cause: Turnover in the Registrar’s office and system issues caused by transitioning online undergraduate students from non-standard terms to traditional terms. Effect: Delays and errors in enrollment reporting to NSLDS. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a spot check for NSLDS enrollment reporting periodically during the academic year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

NSLDS Reporting Errors Planned Corrective Action: Management agrees with this finding. The Registrar's Office has already resolved the system issues that were created by a new process for SP24 that created errors and resulted in students left off enrollment reports. The Registrar has successfully implemented a process to ensure consistency in reporting that can be shown through our submitted reports post Fall of 23'. Prior to each submission, the Registrar now performs a spot check by pulling a SIS enrollment report which helps to cross-reference and confirm the data. Additionally, the Registrar will select 10 random records from the enrollment file for detailed verification of accuracy, and correct any necessary records prior to submitting to NSC. The Registrar has identified some discrepancies between what is reported to NSC and what is pulled by NSLDS and are in the process of collaborating with CIU's IT team to investigate and resolve these issues promptly. Person Responsible for Corrective Action Plan: Elizabeth Haselden, Registrar; Joy Brown, Degree Audit and Data Specialist Anticipated Date of Completion: May 31, 2025

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FY 2023-06-30

$13,129,509 federal awards expended

FAC accepted this audit on December 21, 2023 — management decision was due June 21, 2024.

2023-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: 1. The security program documentation will be updated to reflect actions required by the June 2023 GLBA legislative changes. 2. The information and technology risk management activities logged and captured in supplemental documentation will be included in the master security program documentation going forward. 3. Active technology projects and roadmap initiatives that impact GLBA compliance will be expedited. Person Responsible for Corrective Action Plan: Tirrell Howell, Vice President of Information Technology Anticipated Date of Completion: May 31, 2024

About Special Tests and Provisions →
2023-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001QUESTIONED COSTSOTHER MATTERS

When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $2,670 Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit. Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices. Effect: Title IV funds were not returned timely. Identification as repeat finding, if applicable: 2022-001 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Full finding narrative

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $2,670 Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit. Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices. Effect: Title IV funds were not returned timely. Identification as repeat finding, if applicable: 2022-001 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: In conjunction with the Registrar’s Office, we have implemented the following corrective actions to improve our processes/timeframe for withdrawals: 1) This summer, the Financial Aid Office was added to the workflow in Etrieve (document management system used by CIU) so that 2 of our counselors (one for UG trad and one for online) now receive notifications directly of every withdrawal received by the Registrar’s Office. This allows our office to begin the process of returning funds without the reliance of emails forwarded from the Registrar’s Office. 2) Director and Associate Directors of Financial Aid met with the Registrar and Assistant Registrar on 10/31/23 to discuss how communication and processes could improve between offices. The following are several action items the Registrar will complete on their end that can assist in accomplishing this goal. • Registrar will ask Deans to explain to their faculty that when a student completes an assignment after their module is complete, the date to be entered must be the last date of that module so that our reports will capture the date needed for the return to process correctly. • Registrar will review their current procedures for processing official withdrawals and tighten their turn around time so that the Financial Aid Office can return aid within the required 45 days. 3) CIU made the decision to convert all 5-week UG online classes to 8-week classes starting the 23-24 academic year. These modules now fall within our standard academic calendar which should greatly improve our ability to monitor and process withdrawals for this student population. Person Responsible for Corrective Action Plan: Patty Hix, Director of Financial Aid; Lynsay Shumpert, Associate Director for Online Studies; Elizabeth Haselden, Registrar Anticipated Date of Completion: A follow-up meeting has been set before the end of fall semester to discuss the progress of our action plans with the Registrar.

Prior Finding References

2022-001

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FY 2022-06-30

LOW-RISK AUDITEE$13,558,521 federal awards expended

FAC accepted this audit on November 10, 2022 — management decision was due May 10, 2023.

2022-001
Special Tests & Provisions
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid in a timely manner. There was one student who qualified for the modular exemption who had funds incorrectly returned. There were two students who did not have their Pell awards adjusted for lack of attendance after evaluating their withdrawals. There was one student who had an incorrect R2T4 calculation. Criteria: 34 CFR 668.22 Questioned Costs: $1,625 Context: Out of 51 students tested, 10 students had late returns ($23,175 FDL; $1,561 Pell) ranging from 9 to 231 days late. This was due to a lack of communication between the Registrar and Financial Aid offices that should be triggered by a student?s withdrawal. 1 student met the modular exemption from an R2T4 calculation due to successfully completing classes equivalent to the school?s definition of half-time enrollment, but an R2T4 was processed and funds were returned for the student ($2,932 FDL). This was corrected during the audit. 1 student had their Pell award adjusted for their attendance after an R2T4 had been processed with the incorrect Pell amount considered in the calculation. A second R2T4 was then processed with the correct Pell amount but used the net FDL amounts rather than the original disbursements, which caused an incorrect R2T4 calculation and an over-return of funds ($418 FDL). This was not corrected during the audit. 2 students did not have their Pell awards reduced for their attendance after their withdrawals were evaluated ($1,625 Pell). These were corrected during the audit. Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the Registrar and Financial Aid Offices. Effect: Title IV funds were not returned timely and Pell amounts were not appropriately adjusted for changes in enrollment. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4's are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 20%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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2022-001 Untimely Returns of Title IV Funds and Inaccurate Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid in a timely manner. There was one student who qualified for the modular exemption who had funds incorrectly returned. There were two students who did not have their Pell awards adjusted for lack of attendance after evaluating their withdrawals. There was one student who had an incorrect R2T4 calculation. Criteria: 34 CFR 668.22 Questioned Costs: $1,625 Context: Out of 51 students tested, 10 students had late returns ($23,175 FDL; $1,561 Pell) ranging from 9 to 231 days late. This was due to a lack of communication between the Registrar and Financial Aid offices that should be triggered by a student?s withdrawal. 1 student met the modular exemption from an R2T4 calculation due to successfully completing classes equivalent to the school?s definition of half-time enrollment, but an R2T4 was processed and funds were returned for the student ($2,932 FDL). This was corrected during the audit. 1 student had their Pell award adjusted for their attendance after an R2T4 had been processed with the incorrect Pell amount considered in the calculation. A second R2T4 was then processed with the correct Pell amount but used the net FDL amounts rather than the original disbursements, which caused an incorrect R2T4 calculation and an over-return of funds ($418 FDL). This was not corrected during the audit. 2 students did not have their Pell awards reduced for their attendance after their withdrawals were evaluated ($1,625 Pell). These were corrected during the audit. Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the Registrar and Financial Aid Offices. Effect: Title IV funds were not returned timely and Pell amounts were not appropriately adjusted for changes in enrollment. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4's are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 20%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Finding Number: 2022-001 Untimely Returns of Title IV Funds and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: Three of the four students with inaccurate return of Title IV fund calculations were corrected during the audit. FA Office is in the process of reaching out to the student with an over-return of $418 in FDL for authorization to disburse this amount. FA Office has met with Assistant Registrar for Online Studies and Academic Advising to review the federal regulations for R2T4 in modular programs. The Online Advising and Registrar team were provided with a list of module withdrawal questions that should help to determine if a student is a withdrawal. A copy of questions that were provided to those teams is attached. The following procedures were established between both offices to eliminate untimely and inaccurate return of Title IV funds going forward: If a student is dropped for inactivity/nonparticipation, the remainder of their courses for that payment period are dropped as well. This allows the return of unearned Title IV funds to be completed no later than 45 days after the school determines the LDA. If a student would like to take a break and return to a module that begins later in the payment period, they must provide a statement of intent to return (written confirmation) and the module must begin no later than 45 calendar days after the end of the module the student ceased attending. Financial Aid also met with Associate Registrar and CIU Database Developer to create a report that better captures students who are determined as withdrawals in modular programs. This will assist in monitoring the online student population and achieve more accuracy in reporting. Online Financial Aid team has redistributed workload so that the Associate Director has more time designated to monitor and oversee the R2T4 process. Person Responsible for Corrective Action Plan: Patty Hix, Director of Financial Aid and Lynsay Shumpert, Associate Director for Online Studies Anticipated Date of Completion: Report has been created and we are in the testing phase.

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FY 2021-06-30

LOW-RISK AUDITEE$13,394,856 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 21, 2021 — management decision was due May 21, 2022.

FY 2020-06-30

$11,384,827 federal awards expended

FAC accepted this audit on October 20, 2020 — management decision was due April 20, 2021.

2020-001
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

The University disbursed Cares Act emergency student aid grants to students who were ineligible to receive these funds. Criteria: 18004(a)(1) of the Cares Act Questioned Costs: $28,447 Context: Out of the 626 students awarded Cares Act emergency student aid grants, 2 students with a F1 student visa, 4 distance education students and 45 students not enrolled in the spring term were not eligible to receive the emergency grant aid. Effect: Awarding to ineligible students. Students above were either Title IV ineligible based on having a F1 student visa or were ineligible based on enrollment in an online-only term or did not attend during the spring term when the disaster was declared. Cause: The University used a system generated report that provided some inaccurate information on student enrollment. Furthermore, this report was not compared to the student enrollment listing from the Registrar. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University use institutional resources to fund the emergency grants awarded to ineligible students and award the amount of questioned costs above to eligible students. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.

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2020-001 COVID-19 Ineligible Emergency Student Aid Grants Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.435E COVID-19 Education Stabilization Fund- Student portion Federal Award Identification #: 19/20 Award Year Condition: The University disbursed Cares Act emergency student aid grants to students who were ineligible to receive these funds. Criteria: 18004(a)(1) of the Cares Act Questioned Costs: $28,447 Context: Out of the 626 students awarded Cares Act emergency student aid grants, 2 students with a F1 student visa, 4 distance education students and 45 students not enrolled in the spring term were not eligible to receive the emergency grant aid. Effect: Awarding to ineligible students. Students above were either Title IV ineligible based on having a F1 student visa or were ineligible based on enrollment in an online-only term or did not attend during the spring term when the disaster was declared. Cause: The University used a system generated report that provided some inaccurate information on student enrollment. Furthermore, this report was not compared to the student enrollment listing from the Registrar. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University use institutional resources to fund the emergency grants awarded to ineligible students and award the amount of questioned costs above to eligible students. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.

Corrective Action Plan

Finding Number: 2020-001 COVID-19 Ineligible Emergency Student Aid Grants Planned Corrective Action: CIU will use institutional resources to correct the $28,477.37 in HEERF funds that were inadvertently awarded to ineligible students. The Financial Aid Office has identified eligible students who have continued enrollment at CIU this fall and will work with Accounting Office to send out these additional funds by mid-point of the semester. Person Responsible for Corrective Action Plan: Director of Financial Aid, Patty Hix Anticipated Date of Completion: Mid-point of Fall 2020 semester.

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2020-002
Eligibility
QUESTIONED COSTSOTHER MATTERS

The University disbursed the annual Federal Direct Loans (FDL) in the fall 2019 term for students who were completing the final term of their program. FDL was over awarded since the loans were not properly prorated. Criteria: 34 CFR 685.203 (a), (b), (c) Questioned Costs: $13,086 Context: 1 out of 60 students tested was incorrectly awarded the full annual limit of FDL in the fall term, rather than prorated for the 13 credit hours taken, resulting in an over award of subsidized loans. The University completed a full review concluding that 4 other students who graduated at the end of the fall term had incorrectly received the full FDL. Effect: Over awarding of financial aid. The student identified during the audit was over awarded subsidized loans by $2,278. The 4 other students were over awarded $5,563 in subsidized loans and $5,245 in unsubsidized loans. The over awarded funds for all 5 students were returned to the Department of Education in July 2020. Cause: The University was not aware of the regulations regarding loan proration for students whose final year in their program is the fall term. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University work to develop procedures for monitoring the proration of annual FDL awards for students who are on track to graduate at the end of a fall term. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.

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2020-002 Federal Direct Loan Proration DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Loans Federal Award Identification #: 19/20 Award Year Condition: The University disbursed the annual Federal Direct Loans (FDL) in the fall 2019 term for students who were completing the final term of their program. FDL was over awarded since the loans were not properly prorated. Criteria: 34 CFR 685.203 (a), (b), (c) Questioned Costs: $13,086 Context: 1 out of 60 students tested was incorrectly awarded the full annual limit of FDL in the fall term, rather than prorated for the 13 credit hours taken, resulting in an over award of subsidized loans. The University completed a full review concluding that 4 other students who graduated at the end of the fall term had incorrectly received the full FDL. Effect: Over awarding of financial aid. The student identified during the audit was over awarded subsidized loans by $2,278. The 4 other students were over awarded $5,563 in subsidized loans and $5,245 in unsubsidized loans. The over awarded funds for all 5 students were returned to the Department of Education in July 2020. Cause: The University was not aware of the regulations regarding loan proration for students whose final year in their program is the fall term. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University work to develop procedures for monitoring the proration of annual FDL awards for students who are on track to graduate at the end of a fall term. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.

Corrective Action Plan

Finding Number: 2020-002 Federal Direct Loan Proration Planned Corrective Action: The Financial Aid Office will monitor students who are graduating after the Fall semester and prorate their loans accordingly. Person Responsible for Corrective Action Plan: Director of Financial Aid, Patty Hix Anticipated Date of Completion: Continuous Process

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FY 2019-06-30

$8,032,414 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 15, 2019 — management decision was due April 15, 2020.

FY 2018-06-30

LOW-RISK AUDITEE$6,887,182 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 2, 2018 — management decision was due April 2, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$6,277,065 federal awards expendedNo findings recorded this year

FAC accepted this audit on September 5, 2017 — management decision was due March 5, 2018.

FY 2016-06-30

LOW-RISK AUDITEE$6,155,196 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 9, 2016 — management decision was due April 9, 2017.

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