EIN: 591237047
UEI: MTRTNUHLVRD7
Audited by: CliftonLarsonAllen LLP
Cognizant agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 27, 2026 (24 days from today).
What is a management decision? →FAC accepted this audit on November 6, 2024 — management decision was due May 6, 2025.
During our testing, we noted four instances out of forty students tested, where the R2T4 calculation performed by the Institution utilized incorrect withdrawal dates. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $197. This amount includes $130 of insufficient refunds of direct loan funds, and $327 of excess refunds of Pell funds. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University’s policies and procedures did not ensure calculations were properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance. Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), 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 grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required. Condition: During our testing, we noted four instances out of forty students tested, where the R2T4 calculation performed by the Institution utilized incorrect withdrawal dates. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $197. This amount includes $130 of insufficient refunds of direct loan funds, and $327 of excess refunds of Pell funds. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University’s policies and procedures did not ensure calculations were properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The policy regarding program start dates has been changed and training has occurred to inform the community of the change in processes; data accuracy is consistently monitored by the Registrar’s Office. Name(s) of the contact person(s) responsible for corrective action: Kelsea Gonzalez Planned completion date for corrective action plan: Older program start dates for separated students have been updated with the conclusion of the corrective action plan from 2022-23, ending on 6/30/24, which overlapped with the 2023-24 audit.
2023-001
During our testing of the Direct Loan programs, we selected a sample of forty students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified six students out of the forty tested that had incorrect program begin dates reported to NSLDS. Questioned Costs: None Context: Out of a sample of forty students selected for testing we noted six exceptions. Cause: The University’s processes and controls did not ensure that program begin dates were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 – Federal Direct Student Loans Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (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. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. 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: During our testing of the Direct Loan programs, we selected a sample of forty students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified six students out of the forty tested that had incorrect program begin dates reported to NSLDS. Questioned Costs: None Context: Out of a sample of forty students selected for testing we noted six exceptions. Cause: The University’s processes and controls did not ensure that program begin dates were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct payment periods and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The staff responsible for R2T4 calculations have changed. The staff currently completing these calculations have gone through training and a new tool has been provided, a quality control (QC) spreadsheet. This spreadsheet will be used to double-check payment period dates, used in the system calculation, to ensure ensure it is consistently pulling accurate data and is reviewed weekly. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark Planned completion date for corrective action plan: December 2024
2023-002
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
During our testing, we noted six instances out of forty students tested, where the R2T4 calculation performed by the Institution utilized incorrect withdrawal dates. Questioned Costs: These errors resulted in insufficient refunds to the Department of Education totaling $124. This amount includes $54 of insufficient refunds of direct loan funds, and $70 of Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University’s policies and procedures did not ensure calculations were properly performed. Effect: The University returned insufficient funds to the Department of Education. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2023–001 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), 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 grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required. Condition: During our testing, we noted six instances out of forty students tested, where the R2T4 calculation performed by the Institution utilized incorrect withdrawal dates. Questioned Costs: These errors resulted in insufficient refunds to the Department of Education totaling $124. This amount includes $54 of insufficient refunds of direct loan funds, and $70 of Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University’s policies and procedures did not ensure calculations were properly performed. Effect: The University returned insufficient funds to the Department of Education. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university is researching ways to ensure accuracy in the data entry of withdrawal dates into the system of record. The current process is manual data entry by advising staff creating an opportunity for human input error. Options are being reviewed and could include an integration between the system of record and the eForm the data is collected on or a report that will compare the withdrawal date entered into the system to the source data. Repeat finding, see 2022-002: CAP Completed. Prior year finding had to do with manual data entry directly into the R2T4 calculation. No repeat findings were found in this area of data entry. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: December 2023
2022-002
During our testing of the Direct Loan programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 24 of 40 students tested had one or more instances of noncompliance noted below: I. Twenty-four instances where the student’s program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. One instance where the student’s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing we noted the exceptions as described above. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: YES Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2023–002 – NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 – Federal Direct Student Loans Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (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. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. 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: During our testing of the Direct Loan programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 24 of 40 students tested had one or more instances of noncompliance noted below: I. Twenty-four instances where the student’s program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. One instance where the student’s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing we noted the exceptions as described above. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: YES Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The university completed phase one of the corrective action plan with the practice of matching the program begin date to the term date for new students last year. Accuracy is monitored with reports. No repeat findings found on this population of students. The audit recommendation focuses on continuing students. The university is now in the process of completing phase two, continuing students. Existing active programs will be manually updated by the Registrar’s Office; steps for resolution are already in progress. Using reports to capture students, the team will update the student information system, NSLDS, and NSC, correcting the program begin date to match the term date. This process change will align our reporting procedures with required regulations prior to the close of the 2023 fiscal year (July 2024). 2) The Registrar’s team will provide ongoing instruction to all personnel who have access to process program changes in the student information system. The instructions will direct users to match the begin date of the new program with the term; exceptions will be addressed in the communication. Changes will be monitored by the Registrar’s Office with daily reports. Repeat finding, see 2022-003, item 2. CAP phase 2 focuses on continuing students and is still in process, this involves identifying continuing students with mis-matched data and making the appropriate corrections. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: July 2024
2022-003
FAC accepted this audit on November 28, 2022 — management decision was due May 28, 2023.
Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
Show full finding ▾Hide full finding ▴2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022-001 HEERF Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Immediate action was taken to update the quarterly report and post the updated report to our university?s website. Error was made due to data file showing category under other uses in previous quarterly reports. When new quarterly report was prepared the amount was reported on proper lost revenue line but was not deducted from the other uses total. This resulted in an overstatement of expenditures. An additional step was implemented to confirm total balance with data spreadsheet balance of expenditures. Name(s) of the contact person(s) responsible for corrective action: Jennifer Martell, Controller Planned completion date for corrective action plan: This was immediately corrected when brought to our attention on 5/26/22 for the quarterly report ending 3/31/22 which was originally posted to our website on 4/10/22.
During our testing, we noted one instance out of forty students tested, where the R2T4 calculation performed by the Institution did not exclude the correct amount of days for scheduled breaks of five days or more. In addition, we noted two instances out of forty students tested, where incorrect institutional charges were utilized in the calculation. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $178. This amount includes $187 of excess refunds of direct loan funds, offset by $9 of additional Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
Show full finding ▾Hide full finding ▴2022?002 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 34 CFR 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board), and other educationally-related expenses assessed by the institution. Condition: During our testing, we noted one instance out of forty students tested, where the R2T4 calculation performed by the Institution did not exclude the correct amount of days for scheduled breaks of five days or more. In addition, we noted two instances out of forty students tested, where incorrect institutional charges were utilized in the calculation. Questioned Costs: These errors resulted in excess refunds to the Department of Education totaling $178. This amount includes $187 of excess refunds of direct loan funds, offset by $9 of additional Pell funds that should have been returned. Context: Incorrect inputs in the R2T4 calculation resulted in the calculation discrepancies. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University returned excess funds to the Department of Education. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022-002 Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Report is being created that will allow staff to compare R2T4 manual data entries against source data. Discrepancies will be researched and corrected within 5 business days. Report will be generated weekly and reviewed by the manager over this area. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: Implementation of new quality control R2T4 report planned for October 24, 2022.
During our testing of the Direct Loan and Pell Grant programs, we selected the annual SCHER 1 report and a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted 11 instances of noncompliance related to the SCHER1 report, and 34 of 40 students tested had one or more instances of noncompliance, as noted below: I. Eleven instances where the Institution did not correct errors within the required ten days. When the errors were reported back to the servicer, the resubmission of the records were not corrected and ultimately rejected again. II. Thirty-one instances where the student's program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. Twenty instances where the student?s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. Three instances where the student's change in statuses were not certified and/or received by NSLDS within the required sixty days. 34 CFR 674.19(f)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing, and 1 SCHER1 report for the requirements noted above, we noted the exceptions as described above. Cause: The University?s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institution review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. In addition, we recommend the Institution work with its servicer to determine a procedure is in place to ensure all rejected records are properly reported to NSLDS within 10 days of the initial roster certification and upload. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
Show full finding ▾Hide full finding ▴2022?003 ? NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. 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: During our testing of the Direct Loan and Pell Grant programs, we selected the annual SCHER 1 report and a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted 11 instances of noncompliance related to the SCHER1 report, and 34 of 40 students tested had one or more instances of noncompliance, as noted below: I. Eleven instances where the Institution did not correct errors within the required ten days. When the errors were reported back to the servicer, the resubmission of the records were not corrected and ultimately rejected again. II. Thirty-one instances where the student's program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. Twenty instances where the student?s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. Three instances where the student's change in statuses were not certified and/or received by NSLDS within the required sixty days. 34 CFR 674.19(f)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing, and 1 SCHER1 report for the requirements noted above, we noted the exceptions as described above. Cause: The University?s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institution review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. In addition, we recommend the Institution work with its servicer to determine a procedure is in place to ensure all rejected records are properly reported to NSLDS within 10 days of the initial roster certification and upload. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022-003 NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: please see below Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: December 31, 2022 with continued auditing after. Four areas of deficiency have been identified within our current enrollment reporting process. Specifically, 1) the university did not correct errors within ten days, 2) the program begin date reported to NSLDS (National Student Loan Data System) does not match the university?s records, 3) the student?s program enrollment effective date is incorrectly reported to NSLDS and 4) status changes were not certified and/or received within sixty days. In response to your findings, the Registrar?s Office has created a plan of action to remedy the errors. The enrollment reporting process has new leadership at the university. The findings from the new audit team will be corrected. The corrections will require the university to change current behaviors, practices, and reports. Findings two and three are connected to the program start date entered into Colleague. Currently, when processing a program add or change in Colleague (student information system), the program start date defaults to the first day of the month of the start of the term. In the past admissions and advising have been instructed to enter the upcoming term date as the program start date in the SACP (Student Academic Program) screen of Colleague. Unfortunately, this is not being done consistently and several teams have reverted to using the default date and the issue was not identified prior to reporting. The following outlines the proposed corrective action plan: 1) New and re-entry/re-admit students, program changes, or change of residency a. Effective for student programs starting in Fall 2 2022, the program start date in Colleague will match the start date of the upcoming term or end date of prior term. The operator will manually correct the default date to mirror the first day of the start term or end date of prior term in Colleague. i. If there is a potential issue with the date of the upcoming term, the Registrar?s Office must be consulted prior to committing to an alternate date. 2) Active continuing students a. Phase 1: The Fall 1 2022 census report will be used to generate a list of all currently active students. Each student will be manually reviewed to verify the program effective start date reflects the start of term at the university or start of term for the next declared program/major. Although the start date of a program change is not required to match the start of term for enrollment reporting purposes, this will eliminate processing confusion and increase consistency. i. The first phase of corrections will be completed by October 24, 2022. b. Phase 2: Prior census reports will be used to capture students who had been active in terms from Summer 1 2021 to Fall 1 2022. The program effective start dates will be reviewed and corrected as needed. i. The second phase of corrections will be completed by December 31, 2022. 3) Communication a. Issue a Registrar Communication memorandum (RegCom) outlining the new expectations for assigning the program effective start date, auditing schedule, and implications of errors to the following within the university, by October 24, 2022. i. Registrar team ii. Admissions operations iii. Deans, Chairs, and Program Directors iv. Campus success coaches, faculty advisors, and coordinators v. Center directors and staff 4) Inactive students (have not attended since Summer 1 2021) a. The program effective start date of students who have not been active at the university since the Summer 1 2021 term will be reviewed and updated upon re-entry/re-admit to the university (See bullet 1 above). 5) Report/Audit a. Coordinate with the Department of Information Technology (DoIT) to create a SQL report to pull student information from Colleague, including the student?s start term and declared program effective start date. b. The Registrar?s Office will audit the report weekly to ensure all dates are compliant and accurate prior to generating the enrollment file. 6) Colleague functionality a. Explore the possibility of amending the default date assigned by Colleague. i. This is restricted by the capabilities of the SIS. If unable to amend, we would continue with manual process noted above. Findings one and four relate to the timing of file submission and correcting roster errors. The Registrar will review the university?s reporting procedures and schedule to ensure that student statuses are accurately reported through the servicer to NSLDS within sixty days and errors are corrected within ten days. To do so, the Registrar will: 1) Establish an annual schedule to report student statuses every thirty to sixty days. a. Attention will be given to term dates, withdraw deadlines, as well as weekends and calendar holidays. 2) Create a sub-schedule of timing for correcting errors. This schedule should account for days necessary for the servicer and NSLDS to process the data. 3) Audit the SCHER5 and other reports weekly to ensure any remaining errors are corrected within ten days. By taking the above actions, Saint Leo will have processes in place to establish and maintain procedures to reasonably achieve compliance with NSLDS regulations providing timely and accurate data and audit the effectiveness of our data collection and reporting procedures. The university, specifically the Registrar?s Office, is committed to submitting complete, accurate, and timely enrollment data for Saint Leo University students.
FAC accepted this audit on December 19, 2021 — management decision was due June 19, 2022.
FAC accepted this audit on February 25, 2021 — management decision was due August 25, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FAC accepted this audit on September 3, 2018 — management decision was due March 3, 2019.
FAC accepted this audit on September 27, 2017 — management decision was due March 27, 2018.
FAC accepted this audit on September 5, 2016 — management decision was due March 5, 2017.
GSA_MIGRATION
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2015-001
GSA_MIGRATION
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GSA_MIGRATION
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