EIN: 590668483
UEI: C3B8EZBZSCP3
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 2, 2021. 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 November 2, 2021 (1755 days ago).
What is a management decision? →Of four the four draw down selections made, two periods had drawdowns that did not agree to the amount disbursed to students. Cause: Disbursement rosters are forwarded to the FA Director by the designated FA staff processor. FA Director has confirmed there have been occasions, when a roster was not forwarded and as a result, the disbursement amount was off, causing the drawdown to be off. Currently, there are multiple disbursement rosters run in the course of day. Effect or Potential Effect: As a result, the University received less funding for the selected period than what was allowed. Periods that are not fully reconciled on a monthly basis may result in inaccurate request for awards that can be rejected, delayed, or placed on cash monitored pay system by the Department of Education. Questioned Costs: None. The University requested less than the disbursed amount. Recommendation: We recommend University develop a process whereby all disbursements, by type, are processed, reconciled and authorized on a regular ongoing basis, not less than bi-weekly during the disbursement periods. Responsible Official?s Response and Corrective Action Planned: The office will move to a scheduled disbursement calendar to correct this issue and allow for controlled tracking and confirmation of all disbursement rosters.
Show full finding ▾Hide full finding ▴Criteria: The University must identify the students or parents for whom reimbursement is sought. The requested drawdown should reconcile to the disbursements made to eligible students. Condition: Of four the four draw down selections made, two periods had drawdowns that did not agree to the amount disbursed to students. Cause: Disbursement rosters are forwarded to the FA Director by the designated FA staff processor. FA Director has confirmed there have been occasions, when a roster was not forwarded and as a result, the disbursement amount was off, causing the drawdown to be off. Currently, there are multiple disbursement rosters run in the course of day. Effect or Potential Effect: As a result, the University received less funding for the selected period than what was allowed. Periods that are not fully reconciled on a monthly basis may result in inaccurate request for awards that can be rejected, delayed, or placed on cash monitored pay system by the Department of Education. Questioned Costs: None. The University requested less than the disbursed amount. Recommendation: We recommend University develop a process whereby all disbursements, by type, are processed, reconciled and authorized on a regular ongoing basis, not less than bi-weekly during the disbursement periods. Responsible Official?s Response and Corrective Action Planned: The office will move to a scheduled disbursement calendar to correct this issue and allow for controlled tracking and confirmation of all disbursement rosters.
The Financial Aid Office will move to a scheduled disbursement calendar to correct this issue and allow for controlled tracking and confirmation of all disbursement rosters.
2019-008
For the year ended June 30, 2020, the University was unable to provide a copy of the SCHER 1 report from the NSLDS website to facilitate the testing of whether it is meeting enrollment reporting requirements. Cause: Lack of follow-up with the Registrar?s Office to confirm the report was submitted. Effect or Potential Effect: As a result, it was not possible to determine whether the University is meeting the special tests and provisions requirement to promptly complete and return the Enrollment Reporting roster file to the Department of Education. Recommendation: The University should ensure that it completes and return the Enrollment Reporting roster file within 15 days. Responsible Official?s Response and Corrective Action Planned: The Office of Financial Aid will confirm with the University?s Office of the Registrar that the Enrollment Report is submitted and work to ensure the report is updated timely.
Show full finding ▾Hide full finding ▴Criteria: Under the Pell grant and Federal Loan programs, the University must complete and return the Enrollment Reporting roster file, placed in its Student Aid Internet Gateway mailboxes, by the Department of Education via NSLDS, within 15 days. Condition: For the year ended June 30, 2020, the University was unable to provide a copy of the SCHER 1 report from the NSLDS website to facilitate the testing of whether it is meeting enrollment reporting requirements. Cause: Lack of follow-up with the Registrar?s Office to confirm the report was submitted. Effect or Potential Effect: As a result, it was not possible to determine whether the University is meeting the special tests and provisions requirement to promptly complete and return the Enrollment Reporting roster file to the Department of Education. Recommendation: The University should ensure that it completes and return the Enrollment Reporting roster file within 15 days. Responsible Official?s Response and Corrective Action Planned: The Office of Financial Aid will confirm with the University?s Office of the Registrar that the Enrollment Report is submitted and work to ensure the report is updated timely.
The University was unable to provide a copy of the SCHER 1 report from the NSLDS website to facilitate the testing of whether it is meeting enrollment reporting requirements.
2019-011
FAC accepted this audit on May 11, 2020 — management decision was due November 11, 2020.
For the year ended June 30, 2019, the university had no established policies and procedures to verify information in student aid applications. Numerous files were missing required documentation. Cause: The recently appointed Director of Student Financial Aid stated that the existing policies and procedures are outdated and did not provide copies of them. Effect or Potential Effect: As a result, the university does not meet the compliance requirement to establish written policies and procedures for verifying student financial aid applicant information. Recommendation: The university should develop written policies and procedures for verifying student aid applicant information.
Show full finding ▾Hide full finding ▴Finding 2019-007: Proof of written policies and procedures are in place for verifying student financial aid application information. Student Financial Assistance Cluster CFDA#: 84.063, 84.007, 84.033, 84.268, 84.379 Criteria: Program requirements state that an institution not participating under an ED-approved Quality Assurance Program (QAP), is required to establish written policies and procedures that incorporate the provisions of 34CFR sections 668.51 through 668.61, for verifying student aid applicant information. Condition: For the year ended June 30, 2019, the university had no established policies and procedures to verify information in student aid applications. Numerous files were missing required documentation. Cause: The recently appointed Director of Student Financial Aid stated that the existing policies and procedures are outdated and did not provide copies of them. Effect or Potential Effect: As a result, the university does not meet the compliance requirement to establish written policies and procedures for verifying student financial aid applicant information. Recommendation: The university should develop written policies and procedures for verifying student aid applicant information.
Responsible Official?s Response and Corrective Action Planned: Updates to student status and Pell grant eligibility are typically triggered by an event which includes but may not be limited to: 1) Changes in enrollment from full-time to part-time; the Financial Aid Office (FAO) is notified via the Registrar?s Office (via email). 2) Withdrawals which may results in R2T4 , and 3) Corrections made by a student or FAO counselor which result in an updated ISIR transaction. ISIR records are imported on a regular basis. It appears there were policies and procedures in place on the financial server, but the data was lost during a server crash months back. As such, changes to a student?s eligibility may not have been properly documented.
2018-004
For the year ended June 30, 2019, the total draw down amounts for the two selected months for both FDL and PELL programs were reviewed against the total amounts on the supporting student Disbursement Authorization Rosters and noted discrepancies for all sample sections tested. Cause: Management did not provide an explanation for the discrepancies. Effect or Potential Effect: As a result, the university does not meet the cash management requirement that draw down amounts must not exceed the amount immediately needed to disburse funds to students or parents. Section III: Federal Awards and State Financial Assistance Findings (Continued) Questioned Costs: $ 824,829 Recommendation: The university should ensure that draw down of funds does not exceed the amount immediately needed to disburse funds to students or parents.
Show full finding ▾Hide full finding ▴Finding 2019-008: Approval of drawdown requests Student Financial Assistance Cluster CFDA#: 84.063, 84.268 Criteria: Program requirements state that the institution?s draw down of funds must not exceed the amount immediately needed to disburse funds to students or parents. Condition: For the year ended June 30, 2019, the total draw down amounts for the two selected months for both FDL and PELL programs were reviewed against the total amounts on the supporting student Disbursement Authorization Rosters and noted discrepancies for all sample sections tested. Cause: Management did not provide an explanation for the discrepancies. Effect or Potential Effect: As a result, the university does not meet the cash management requirement that draw down amounts must not exceed the amount immediately needed to disburse funds to students or parents. Section III: Federal Awards and State Financial Assistance Findings (Continued) Questioned Costs: $ 824,829 Recommendation: The university should ensure that draw down of funds does not exceed the amount immediately needed to disburse funds to students or parents.
Responsible Official?s Response and Corrective Action Planned: During the audit year in question, there are emails documenting that the former Financial Aid Director directly provided authorization to the Budget & Finance Director of the exact amounts to draw down which would coincide with the student awards. Please note that Finance cannot initiate a draw down, but rather, Financial Aid must initiate it with the amount, type of funds, program, and year and term. At that point, the Director of Budgeting and Cash Management draws the funds down and they are wired to the University Restricted DEFAS and Direct Loan cash accounts. Monthly reconciliations are performed of each of these cash accounts by the University by the senior accountant and reviewed by the Controller. Additionally, if funds had been drawn down in excess of awards, the US Dept. of Education would have notified the University promptly. Although a system crash is preventing the University from locating the exact amount of the awards by student being drawn down, the University is confident that the compensating controls in place allowed for the transaction to be accurately drawn down and recorded.
For the year ended June 30, 2019, three male students of the twenty-one students tested for the Federal Pell Grant Program and eight male students of the thirty-seven students tested for the Federal Direct Loan Program, had no evidence of temporary or permanent exemption on file, were not registered under Section 3 of the Military Service Act. Cause: Management did not provide an explanation for the discrepancies. Effect or Potential Effect: As a result, the university does not meet the eligibility requirement that male students must have registered under Section 3 of the Military Service Act, with the Selective Service unless the student is below the age of 18 or was born before Jan 1, 1960, is enrolled in an officer procurement program, or is a commissioned officer of the Public Health Service and/or a member of the Reserve of the Public Health Service who is on active duty. Questioned Costs: The total award amount in the amount of $177,307 to these students under both federal programs represents the questioned costs. The total questioned costs represent approximately 19% of the total amount disbursed under both programs for the sample tested. Recommendation: The university should ensure that the Federal Pell Grant Award and Federal Direct Loans are only made to eligible male students who have registered under Section 3 of the Military Service Act.
Show full finding ▾Hide full finding ▴Finding 2019-009: Selective service requirements Student Financial Assistance Cluster CFDA#: 84.063, 84.007, 84.033, 84.268, 84.379 Criteria: Program requirements state that male students must have registered under Section 3 of the Military Service Act, with the Selective Service unless the student is below the age of 18 or was born before Jan 1, 1960, is enrolled in an officer procurement program, or is a commissioned officer of the Public Health Service and/or a member of the Reserve of the Public Health Service who is on active duty. Condition: For the year ended June 30, 2019, three male students of the twenty-one students tested for the Federal Pell Grant Program and eight male students of the thirty-seven students tested for the Federal Direct Loan Program, had no evidence of temporary or permanent exemption on file, were not registered under Section 3 of the Military Service Act. Cause: Management did not provide an explanation for the discrepancies. Effect or Potential Effect: As a result, the university does not meet the eligibility requirement that male students must have registered under Section 3 of the Military Service Act, with the Selective Service unless the student is below the age of 18 or was born before Jan 1, 1960, is enrolled in an officer procurement program, or is a commissioned officer of the Public Health Service and/or a member of the Reserve of the Public Health Service who is on active duty. Questioned Costs: The total award amount in the amount of $177,307 to these students under both federal programs represents the questioned costs. The total questioned costs represent approximately 19% of the total amount disbursed under both programs for the sample tested. Recommendation: The university should ensure that the Federal Pell Grant Award and Federal Direct Loans are only made to eligible male students who have registered under Section 3 of the Military Service Act.
Responsible Official?s Response and Corrective Action Planned: Male students must register at the age of 18 to be eligible to obtain federal grants and loans. The students in question were likely not 18 at the time they filed their FAFSA. Updated registration is confirmed by verifying the most recent ISIR for the award year in question.
2018-010
For the year ended June 30, 2019, management was unable to provide a written copy or verbal overview of the procedures in place regarding the updating of student status for both programs. Cause: Management did not provide an explanation for the non-existent procedures. Effect or Potential Effect: As a result, the University does not meet the special tests and provisions requirement to have procedures in place regarding the updating of student status for the Federal Pell Grant and Direct Loan Programs. Recommendation: The University should develop and implement procedures regarding the updating of student status for the Federal Pell Grant and Direct Loan Programs.
Show full finding ▾Hide full finding ▴Finding 2019-010: Student status procedures for Pell and Direct Loans Student Financial Assistance Cluster CFDA#: 84.063, 84.268 Criteria: Program requirements state that the university should have procedures in place regarding the updating of student status for the Federal Pell Grant and Direct Loan Programs. Condition: For the year ended June 30, 2019, management was unable to provide a written copy or verbal overview of the procedures in place regarding the updating of student status for both programs. Cause: Management did not provide an explanation for the non-existent procedures. Effect or Potential Effect: As a result, the University does not meet the special tests and provisions requirement to have procedures in place regarding the updating of student status for the Federal Pell Grant and Direct Loan Programs. Recommendation: The University should develop and implement procedures regarding the updating of student status for the Federal Pell Grant and Direct Loan Programs.
Responsible Official?s Response and Corrective Action Planned: Updates to student status and Pell grant eligibility are typically triggered by an event which includes but may not be limited to: 1) Changes in enrollment from full-time to part-time; the Financial Aid Office (FAO) is notified via the Registrar?s Office (via email). 2) Withdrawals which may results in R2T4 , and 3) Corrections made by a student or FAO counselor which result in an updated ISIR transaction. ISIR records are imported on a regular basis. It appears there were policies and procedures in place on the financial server, but the data was lost during a server crash months back. As such, changes to a student?s eligibility may not have been properly documented.
2018-006
For the year ended June 30, 2019, the University was unable to provide a copy of the SCHER 1 report from the NSLDS website to facilitate the testing of whether it is meeting enrollment reporting requirements. Cause: The University was constantly experiencing computer and IT related system problems and thus unable to generate the SCHER 1 report. Effect or Potential Effect: As a result, it was not possible to determine whether the University is meeting the special tests and provisions requirement to promptly complete and return the Enrollment Reporting roster file to the Department of Education. Recommendation: The University should ensure that it completes and return the Enrollment Reporting roster file within 15 days. Section III: Federal Awards and State Financial Assistance Findings (Continued)
Show full finding ▾Hide full finding ▴Finding 2019-011: Enrollment Reporting Roster File Student Financial Assistance Cluster CFDA#: 84.063, 84.268 Criteria: Under the Pell grant and Federal Loan programs, the University must complete and return the Enrollment Reporting roster file, placed in its Student Aid Internet Gateway mailboxes, by the Department of Education via NSLDS, within 15 days. Condition: For the year ended June 30, 2019, the University was unable to provide a copy of the SCHER 1 report from the NSLDS website to facilitate the testing of whether it is meeting enrollment reporting requirements. Cause: The University was constantly experiencing computer and IT related system problems and thus unable to generate the SCHER 1 report. Effect or Potential Effect: As a result, it was not possible to determine whether the University is meeting the special tests and provisions requirement to promptly complete and return the Enrollment Reporting roster file to the Department of Education. Recommendation: The University should ensure that it completes and return the Enrollment Reporting roster file within 15 days. Section III: Federal Awards and State Financial Assistance Findings (Continued)
Responsible Official?s Response and Corrective Action Planned: Due to Financial Aid server issues at the time of the audit, the Interim Director of Financial Aid did not have access to EdConnect to import the SCHER1/Enrollment report. Such server issues are partially resolved, and the Interim Director now has access to import enrollment reports and has a copy of the enrollment report data for 2018-19.
For the year ended June 30, 2019, of the eight (8) items selected, there were two (2) instances in which Title IV funds were returned significantly later than 45 days for students who withdrew from the university programs. Cause: Management was unable to explain the delay in return of Title IV funds as this occurred prior to her assuming the role. Effect or Potential Effect: As a result, the university does not meet the Return of Title IV Funds compliance requirements. Recommendation: The University should ensure that it accurately computes and promptly returns Title IV funds to the ED.
Show full finding ▾Hide full finding ▴Finding 2019-012: Prompt Return of Title IV Funds Student Financial Assistance Cluster CFDA#: 84.063, 84.007, 84.033, 84.268, 84.379 Criteria: Program requirements state that when a recipient of Title IV grant or loan assistance withdraws from an institution or never attended during a payment period or period of enrollment, the unearned portion of Title IV Funds disbursed must be computed and promptly returned to the Department of Education. For students who began attendance at the university, the required time frame for return of funds is 45 days. For students who never attended the university, the required time frame is 30 days. Condition: For the year ended June 30, 2019, of the eight (8) items selected, there were two (2) instances in which Title IV funds were returned significantly later than 45 days for students who withdrew from the university programs. Cause: Management was unable to explain the delay in return of Title IV funds as this occurred prior to her assuming the role. Effect or Potential Effect: As a result, the university does not meet the Return of Title IV Funds compliance requirements. Recommendation: The University should ensure that it accurately computes and promptly returns Title IV funds to the ED.
Responsible Official?s Response and Corrective Action Planned: The correct return to Title IV calculations was returned after the 45 day expected return dates. The University has realigned its internal procedures and has a new Interim Financial Aid Director in place to ensure timely refunds occur in compliance with federal regulations.
2018-008
FAC accepted this audit on February 5, 2019 — management decision was due August 5, 2019.
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2017-003
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2017-003
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FAC accepted this audit on January 17, 2018 — management decision was due July 17, 2018.
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