EIN: 596605703
UEI: HP7ND1CMGMD4
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 5, 2024. 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 June 5, 2025 (450 days ago).
What is a management decision? →During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 30 students: 11 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS 6 instances where the student status change was not reported within the required time frame Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Loan Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that schools must update the secretary with pertinent information within 30 days (unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days) after the date the school discovers a student changed enrollment from half time/full time/graduate/withdrawal/etc. Section 4.4.2 of the NSLDS Enrollment Reporting Guide (Circa November 2018) establishes the definition of the effective date, certification date, and received date. Condition: During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 30 students: 11 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS 6 instances where the student status change was not reported within the required time frame Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable
2023-002
During our testing we noted instances where the wrong disbursement date was reported to COD. Questioned costs: None Context: Of the 60 disbursements tested, we noted 9 instances where the wrong disbursement date was reported. Cause: University’s policies and procedures did not ensure compliance. Effect: Noncompliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2023-005. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Student Loans, 84.063 – Pell Grant Program Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student’s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education (the Department) or with institutional funds in advance of receiving Title IV program funds. This is the date that a school must report to the COD System as the actual disbursement date for a Direct Loan, as distinguished from the anticipated disbursement date. Condition: During our testing we noted instances where the wrong disbursement date was reported to COD. Questioned costs: None Context: Of the 60 disbursements tested, we noted 9 instances where the wrong disbursement date was reported. Cause: University’s policies and procedures did not ensure compliance. Effect: Noncompliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2023-005. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable
2023-005
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 13 students: • 8 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS • 10 instances for which the student's status was not reported timely • 13 instances in which the student's enrollment was not certified timely • 11 instances where the enrollment effective date was incorrect per NSLDS • 6 instances for which the student's status was not reported to NSLDS Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2022-003. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2023–002 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Loan Program Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that schools must update the secretary with pertinent information within 30 days (unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days) after the date the school discovers a student changed enrollment from half time/full time/graduate/withdrawal/etc. Section 4.4.2 of the NSLDS Enrollment Reporting Guide (Circa November 2018) establishes the definition of the effective date, certification date, and received date. Condition: During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 13 students: • 8 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS • 10 instances for which the student's status was not reported timely • 13 instances in which the student's enrollment was not certified timely • 11 instances where the enrollment effective date was incorrect per NSLDS • 6 instances for which the student's status was not reported to NSLDS Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2022-003. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
2023-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Hodges University's enrollment and withdrawal policies did not align with the department of education requirements. In addition, internal controls in place were insufficient. Action taken in response to finding: Hodges University is updating its policies to follow the federal policies and best practices in order to remain compliant; that update will reflect as an addendum to the catalog. We have implemented additional internal controls to ensure the timeliness and accuracy of future reporting, and compliance. Name(s) of the contact person(s) responsible for corrective action: Nicole Hurley, Director of University Registrar, Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost. Planned completion date for corrective action plan: Effective immediately
2022-003
During our testing it was noted that the University did not return certain unclaimed checks within the required time frame. Questioned costs: Known questioned costs totaling $9,284. Context: We identified 27 checks totaling $9,284 related to Title IV funding that were outstanding for more than 240 days as of June 30, 2023. Cause: The University’s policies and procedures did not ensure that the checks were returned to the Secretary in a timely manner. Effect: Noncompliance with the 240 day requirement. Repeat Finding: Yes, prior year finding 2022-004. Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2023–003 240 Day Requirement for Unclaimed Checks Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Student Loans, 84.063 – Pell Grant Program, 84.007 – Supplemental Education Opportunity Grant program Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: During our testing it was noted that the University did not return certain unclaimed checks within the required time frame. Questioned costs: Known questioned costs totaling $9,284. Context: We identified 27 checks totaling $9,284 related to Title IV funding that were outstanding for more than 240 days as of June 30, 2023. Cause: The University’s policies and procedures did not ensure that the checks were returned to the Secretary in a timely manner. Effect: Noncompliance with the 240 day requirement. Repeat Finding: Yes, prior year finding 2022-004. Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Views of responsible officials: See Corrective Action Plan prepared by the University.
2023-003 240-Day Requirement for Unclaimed Checks Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The University continuously attempted to refund the student checks. Action taken in response to finding: The Financial Aid and Student Accounts offices will work diligently to ensure the University's compliance with the federal regulations and deadlines regarding unclaimed properties. Name(s) of the contact person(s) responsible for corrective action: Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost Planned completion date for corrective action plan: April 30, 2024
2022-004
During our testing we noted one instance where the University used the incorrect withdrawal date in the R2T4 calculation. Questioned costs: Known questioned costs totaling $27, likely questioned costs totaling $91. Context: In our sample of 13 students, we identified 1 student where the wrong withdrawal date was used, resulting in a $27 error in the R2T4 calculation. Cause: The University’s policies and procedures did not ensure that the correct withdrawal date was used in the calculation. Effect: An incorrect amount was returned to the Department of Education. Repeat Finding: No. Recommendation: We recommend that the University review its policies and procedures to ensure R2T4 calculations are performed accurately. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2023–004 Return to Title IV (R2T4) Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.063 – Federal Pell Grant Program Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: According to 34 CFR 668.22(e)(1) The amount of title IV grant or loan assistance that is earned by the student is calculated by— (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. Condition: During our testing we noted one instance where the University used the incorrect withdrawal date in the R2T4 calculation. Questioned costs: Known questioned costs totaling $27, likely questioned costs totaling $91. Context: In our sample of 13 students, we identified 1 student where the wrong withdrawal date was used, resulting in a $27 error in the R2T4 calculation. Cause: The University’s policies and procedures did not ensure that the correct withdrawal date was used in the calculation. Effect: An incorrect amount was returned to the Department of Education. Repeat Finding: No. Recommendation: We recommend that the University review its policies and procedures to ensure R2T4 calculations are performed accurately. Views of responsible officials: See Corrective Action Plan prepared by the University.
2023-004 Return to Title IV (R2T4) Recommendation: We recommend that the University review its policies and procedures to ensure R2T4 calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned completion date for corrective action plan: Effective immediately Reason for finding: The University policies were not in alignment with the with the federal policies and best practices. Action taken in response to finding: Hodges University is updating its policies to follow the federal policies and best practices in order to remain compliant; that update will reflect as an addendum to the catalog. Name(s) of the contact person(s) responsible for corrective action: Nicole Hurley, Director of University Registrar, Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost
During our testing we noted instances where the wrong disbursement date was reported to COD. Questioned costs: None Context: Of the 148 disbursements tested, we noted 9 instances where the wrong disbursement date was reported. Cause: University’s policies and procedures did not ensure compliance. Effect: Noncompliance with the reporting requirements. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2023–005 Common Origination and Disbursement (COD) reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Student Loans, 84.063 – Pell Grant Program Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student’s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education (the Department) or with institutional funds in advance of receiving Title IV program funds. This is the date that a school must report to the COD System as the actual disbursement date for a Direct Loan, as distinguished from the anticipated disbursement date. Condition: During our testing we noted instances where the wrong disbursement date was reported to COD. Questioned costs: None Context: Of the 148 disbursements tested, we noted 9 instances where the wrong disbursement date was reported. Cause: University’s policies and procedures did not ensure compliance. Effect: Noncompliance with the reporting requirements. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
2023-005 Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Due to unforeseen technical issues and outdated procedures. Action taken in response to finding: The University is updating the procedures and internal controls to improve the timeliness of reporting. Hodges University is also working closely with our software providers to ensure the transmittals are working in both directions, and that the systems are communicating properly. Name(s) of the contact person(s) responsible for corrective action: Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost Planned completion date for corrective action plan: Effective immediately
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
During our tested we noted certain roster files submissions where some of the error records were not corrected and resubmitted back to NSLDS within the 10-day requirement. Questioned costs: None. Context: 9 out of 12 enrollment rosters submitted during year under audit were not resubmitted within 10 days. Cause: Roster files were not resubmitted within 10 days to correct error records. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2021-002. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2022?002 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Loan Program Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that upon receipt of the Enrollment report from the Secretary a school must update all information included in the report to the secretary within the manner and format prescribed and within the time frame prescribed by the secretary (15 days). If the roster file turned contains records that do not pass the NSLDS enrollment reporting edits, the institution will receive a response file with the records that didn?t pass. Within 10 days the institution needs to make the necessary corrections to these records and resubmit them. Condition: During our tested we noted certain roster files submissions where some of the error records were not corrected and resubmitted back to NSLDS within the 10-day requirement. Questioned costs: None. Context: 9 out of 12 enrollment rosters submitted during year under audit were not resubmitted within 10 days. Cause: Roster files were not resubmitted within 10 days to correct error records. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2021-002. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
2022-002 National Student Loan Data System (NSLDS) Error Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Inconsistencies of status within student?s academic records maintained by the registrar?s office. Action taken in response to finding: The registrar?s office has been made aware of the inconsistencies and reporting errors. The registrar?s office will follow federal policies and best practices in order to remain compliant. Name(s) of the contact person(s) responsible for corrective action: Josh Carcopa/Nicole Hurley Planned completion date for corrective action plan: Effective Immediately.
2021-002
Incorrect or untimely reporting by the University of students? changes in status during the year under audit. Questioned costs: None. Context: In our sample of 21 students, we noted the following discrepancies: ? Discrepancies with the program lengths reported to NSLDS ? 1 instance of an incorrect program enrollment date reported to NSLDS ? 2 instances of student statuses not being reported to NSLDS in a timely manner ? 9 instances of incorrect student enrollment effective dates reported to NSLDS ? 4 instances of incorrect student status being reported to NSLDS Cause: The University?s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2021-003. Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2022?003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Loan Program Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. Condition: Incorrect or untimely reporting by the University of students? changes in status during the year under audit. Questioned costs: None. Context: In our sample of 21 students, we noted the following discrepancies: ? Discrepancies with the program lengths reported to NSLDS ? 1 instance of an incorrect program enrollment date reported to NSLDS ? 2 instances of student statuses not being reported to NSLDS in a timely manner ? 9 instances of incorrect student enrollment effective dates reported to NSLDS ? 4 instances of incorrect student status being reported to NSLDS Cause: The University?s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2021-003. Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
2022-003 National Student Loan Data System (NSLDS) Error Reporting Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Inconsistencies of status within student?s academic and enrollment records maintained by the registrar?s office. Action taken in response to finding: The registrar?s office has been made aware of the inconsistencies and reporting errors. The registrar?s office will follow federal policies and best practices in order to remain compliant. Name(s) of the contact person(s) responsible for corrective action: Joshua Carcopa/Nicole Hurley Planned completion date for corrective action plan: Effective Immediately.
2021-003
During our testing it was noted that the University did not return certain unclaimed refund checks within the required time frame. Questioned costs: Known questioned costs totaling $2,183. Context: We identified 13 checks totaling $2,183 related to return of Title IV funding that were outstanding for more than 240 days as of June 30, 2022. Cause: The University?s policies and procedures did not ensure that the checks were returned to the Secretary in a timely manner. Effect: Noncompliance with the 240 day requirement. Repeat Finding: No. Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2022?004 240 Day Requirement for Unclaimed R2T4 Checks Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Student Loans, 84.063 ? Pell Grant Program, 84.007 ? Supplemental Education Opportunity Grant program, 84.033 ? Federal Work Study Program Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: During our testing it was noted that the University did not return certain unclaimed refund checks within the required time frame. Questioned costs: Known questioned costs totaling $2,183. Context: We identified 13 checks totaling $2,183 related to return of Title IV funding that were outstanding for more than 240 days as of June 30, 2022. Cause: The University?s policies and procedures did not ensure that the checks were returned to the Secretary in a timely manner. Effect: Noncompliance with the 240 day requirement. Repeat Finding: No. Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Views of responsible officials: See Corrective Action Plan prepared by the University.
2022-004 240 Day Requirement of Unclaimed R2T4 Checks Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The university continuously attempted to refund the student checks and new leadership was unaware of the 240 days deadline. Action taken in response to finding: Finance has been made aware of federal regulations and deadlines regarding unclaimed properties. Name(s) of the contact person(s) responsible for corrective action: Linda Nguyen Planned completion date for corrective action plan: Effective immediately.
During our testing it was noted certain loan awards that were made in the wrong amounts. Questioned costs: Known questioned costs totaling $3,250, likely questioned costs totaling $52,546. Context: In our sample of 42 students receiving direct loans, we identified one subsidized loan under-award of $4,535 and one unsubsidized loan over-award of $1,285. Cause: The University?s policies and procedures did not ensure that the loan awards were in the correct amounts. Effect: Improper awarding of direct loans. Repeat Finding: No. Recommendation: We recommend that the college ensures they have appropriate policies and procedures as well as safeguards in place to ensure loan award amounts are properly determined. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2022?005 Direct Loan Awards Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized and unsubsidized loan amounts for students based on their dependency status, year of education, and other factors. Per the Code of Federal Regulations, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student?s estimated cost of attendance for the period of enrollment for which the loan is intended less the student?s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower?s expected family contribution for that period. Condition: During our testing it was noted certain loan awards that were made in the wrong amounts. Questioned costs: Known questioned costs totaling $3,250, likely questioned costs totaling $52,546. Context: In our sample of 42 students receiving direct loans, we identified one subsidized loan under-award of $4,535 and one unsubsidized loan over-award of $1,285. Cause: The University?s policies and procedures did not ensure that the loan awards were in the correct amounts. Effect: Improper awarding of direct loans. Repeat Finding: No. Recommendation: We recommend that the college ensures they have appropriate policies and procedures as well as safeguards in place to ensure loan award amounts are properly determined. Views of responsible officials: See Corrective Action Plan prepared by the University.
2022-005 Direct Loan Awards Recommendation: We recommend that the college ensures they have appropriate policies and procedures as well as safeguards in place to ensure loan award amounts are properly determined. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Student grade level inconsistent throughout the academic record generating an over/under award at the time of packaging Direct Loan awards Action taken in response to finding: Requested the registrar?s office that student record is maintained accurately of the student?s grade level progression history. Name(s) of the contact person(s) responsible for corrective action: Joshua Carcopa/Nicole Hurley Planned completion date for corrective action plan: June 30, 2023.
During our testing we noted one instance where the University did not return funds to the Department of Education. Questioned costs: Known questioned costs totaling $740, likely questioned costs totaling $3,808. Context: In our sample of 7 students, we identified one student where Pell funds of $740 were not returned to the Department of Education. The University submitted a request to return funds through COD, but the request did not go through. Cause: The University?s policies and procedures did not ensure that the refund was made in a timely manner. Effect: Funds were not returned to the Department of Education. Repeat Finding: No. Recommendation: We recommend that the college ensures they have appropriate policies and procedures as well as safeguards in place to ensure return of Title IV funds are made in a timely manner. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2022?006 Return of Title IV (R2T4) Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.063 ? Federal Pell Grant Program Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(e)(4) states the total amount of unearned title IV assistance must be returned within 45 days after the date of the institution's determination that the student withdrew. Condition: During our testing we noted one instance where the University did not return funds to the Department of Education. Questioned costs: Known questioned costs totaling $740, likely questioned costs totaling $3,808. Context: In our sample of 7 students, we identified one student where Pell funds of $740 were not returned to the Department of Education. The University submitted a request to return funds through COD, but the request did not go through. Cause: The University?s policies and procedures did not ensure that the refund was made in a timely manner. Effect: Funds were not returned to the Department of Education. Repeat Finding: No. Recommendation: We recommend that the college ensures they have appropriate policies and procedures as well as safeguards in place to ensure return of Title IV funds are made in a timely manner. Views of responsible officials: See Corrective Action Plan prepared by the University.
2022-006 Return of Title IV (R2T4) Recommendation: We recommend that the college ensures they have appropriate policies and procedures as well as safeguards in place to ensure return of Title IV funds are made in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Return of Title IV (R2T4) was not processed in a timely manner due to late status changes reported from academics. Action taken in response to finding: Provided federal guidance to registrar?s office to process attendance taking and status changes in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Joshua Carcopa/Nicole Hurley Planned completion date for corrective action plan: Effective Immediately.
Non-compliance with reporting requirements under HEERF Questioned costs: None Context: ? We were not able to obtain documentation to demonstrate that the quarterly reporting for institutional and student expenditures was done in a timely manner. ? We were not able to obtain documentation of approval for the quarterly student reporting, the quarterly institutional reporting, or the annual report. ? We noted instances where the information in the reports did not agree to supporting documentation. This applied to one of the three quarterly institutional reports and the annual report. ? The three quarterly student reports omitted information on the number of students wo were eligible to receive funding. Cause: University?s policies and procedures did not ensure compliance. Effect: Non-compliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2021-004. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2022?007 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) 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: Non-compliance with reporting requirements under HEERF Questioned costs: None Context: ? We were not able to obtain documentation to demonstrate that the quarterly reporting for institutional and student expenditures was done in a timely manner. ? We were not able to obtain documentation of approval for the quarterly student reporting, the quarterly institutional reporting, or the annual report. ? We noted instances where the information in the reports did not agree to supporting documentation. This applied to one of the three quarterly institutional reports and the annual report. ? The three quarterly student reports omitted information on the number of students wo were eligible to receive funding. Cause: University?s policies and procedures did not ensure compliance. Effect: Non-compliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2021-004. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
2022-007 Higher Education Emergency Relief Fund (HEERF) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Misunderstanding of correct way to handle the accounting of the HEERF. Action taken in response to finding: We have adjusted our policies and provided training to prevent future inaccuracies in reporting when dealing with special funding. Name(s) of the contact person(s) responsible for corrective action: Melissa Mitro Planned completion date for corrective action plan: Effective immediately.
2021-004
FAC accepted this audit on March 7, 2022 — management decision was due September 7, 2022.
During our testing it was noted that certain disbursement dates reported to COD did not match the disbursement date in the student account. Questioned costs: None. Context: During our testing of Reporting to COD, we noted discrepancies in disbursement dates per the student?s account ledger and as reported to COD in 15 of the 80 students in our sample receiving Pell and/or Direct Loans. Cause: Turnover within the Student Financial Aid Department and the University?s processes and controls did not identify the errors in reporting of disbursement dates to COD. Effect: Student loan interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursement dates to COD to ensure that student information is reported accurately. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2021?001 Common Origination and Disbursement Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Student Loans, 84.063 ? Pell Grant Program Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing it was noted that certain disbursement dates reported to COD did not match the disbursement date in the student account. Questioned costs: None. Context: During our testing of Reporting to COD, we noted discrepancies in disbursement dates per the student?s account ledger and as reported to COD in 15 of the 80 students in our sample receiving Pell and/or Direct Loans. Cause: Turnover within the Student Financial Aid Department and the University?s processes and controls did not identify the errors in reporting of disbursement dates to COD. Effect: Student loan interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursement dates to COD to ensure that student information is reported accurately. Views of responsible officials: See Corrective Action Plan prepared by the University.
2021-001 Common Origination and Disbursement Reporting Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursement dates to COD to ensure that student information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Turnover within the Student Financial Aid Department and the University's processes and controls did not identify the errors in reporting of disbursement dates to COD. Action taken in response to finding: The new Director of Financial Aid hired in August 2021 has identified reporting concerns and is working in collaboration with the Office of Student Accounts to ensure timely reporting to a student's account and COD disbursements. Name(s) of the contact person(s) responsible for corrective action: Ivette Valentin Planned completion date for corrective action plan: Corrective action plan completed prior to audit report issue date.
During our tested we noted certain roster files submissions where some of the error records were not corrected and resubmitted back to NSLDS within the 10-day requirement. Questioned costs: None. Context: 10 out of 12 enrollment rosters submitted during year under audit were not resubmitted within 10 days. Cause: Legacy data continues to be reflected in NSLDS reporting. Hodges worked with NSC last year to clean-up legacy data. Hodges will need to work with NSC again to see why new legacy data continues to be reported. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to Enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2021?002 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Loan Program Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that upon receipt of the Enrollment report from the Secretary a school must update all information included in the report to the secretary within the manner and format prescribed and within the time frame prescribed by the secretary (15 days). If the roster file turned contains records that do not pass the NSLDS enrollment reporting edits, the institution will receive a response file with the records that didn?t pass. Within 10 days the institution needs to make the necessary corrections to these records and resubmit them. Condition: During our tested we noted certain roster files submissions where some of the error records were not corrected and resubmitted back to NSLDS within the 10-day requirement. Questioned costs: None. Context: 10 out of 12 enrollment rosters submitted during year under audit were not resubmitted within 10 days. Cause: Legacy data continues to be reflected in NSLDS reporting. Hodges worked with NSC last year to clean-up legacy data. Hodges will need to work with NSC again to see why new legacy data continues to be reported. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to Enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.
2021-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to Enrollment rosters to NSLDS. Explanation of disagreement with audit finding : There is no disagreement with the audit finding. Reason for finding: Legacy data continues to be reflected in NSLDS reporting. Hodges worked with NSC last year to clean-up legacy data. Hodges will need to work with NSC again to see why new legacy data continues to be reported. Action taken in response to finding : Office of the Registrar will work in concert with National Student Clearinghouse to resolve rejected NSLDS errors that stem from when the university had two campus codes. Name(s) of the contact person(s) responsible for corrective action: Josh Carcopa Planned completion date for corrective action plan: March 1, 2022
Incorrect or untimely reporting by the University of students? changes in status during the 2020-2021 award year under audit. Questioned costs: None. Context: In our sample of 22 students, we noted the following discrepancies: ? 3 students' enrolment statuses per institution?s records did not agree to NSLDS. ? 15 students' status change effective dates did not match the effective dates in NSLDS. ? 2 students' status changes were not reported within 60 days to NSLDS ? 4 students' program length did not match with the program length per NSLDS ? 4 students' program effective date did not match the program-level effective date per NSLDS Cause: There is a disconnect between NSC reporting and how that data is then transmitted for NSLDS reporting. Additionally, there is a conflict between data reporting requirements and Hodges? term structure. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2021?003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Loan Program Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: Incorrect or untimely reporting by the University of students? changes in status during the 2020-2021 award year under audit. Questioned costs: None. Context: In our sample of 22 students, we noted the following discrepancies: ? 3 students' enrolment statuses per institution?s records did not agree to NSLDS. ? 15 students' status change effective dates did not match the effective dates in NSLDS. ? 2 students' status changes were not reported within 60 days to NSLDS ? 4 students' program length did not match with the program length per NSLDS ? 4 students' program effective date did not match the program-level effective date per NSLDS Cause: There is a disconnect between NSC reporting and how that data is then transmitted for NSLDS reporting. Additionally, there is a conflict between data reporting requirements and Hodges? term structure. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
2021-003 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: There is a disconnect between NSC reporting and how that data is then transmitted for NSLDS reporting. Additionally, there is a conflict between data reporting requirements and Hodges' term structure. Action taken in response to finding : Office of the Registrar will work with National Student Clearinghouse to ensure reporting parameters for enrollment reporting are aligned with reporting parameters for NSLDS reporting . Name(s) of the contact person(s) responsible for corrective action: Josh Carcopa Planned completion date for corrective action plan : March 1, 2022
Non-compliance with reporting requirements under HEERF Questioned costs: None Context: ? We were unable to identify a specific control in place to ensure that any errors would be prevented or detected in a timely manner ? The 45 day report was not submitted within the required time frame ? In the 3/31/2021 quarterly reporting, one of the seven required items was not disclosed ? In the 7/23/2020 quarterly reporting, all of the seven required items were disclosed, but we did not receive supporting documentation for one of the disclosures ? Item E (Institutional Expenditures) in the annual report was not correctly reported Cause: University staff reviewed all published guidance on reporting deadlines and interpreted the guidance to mean that the deadline for the report was slightly later than later guidance clarified it to be. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2021?004 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) 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. The initial reporting for this grant requires the report to be submitted to the institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This requirement was changed to quarterly on 8/31/2020. Condition: Non-compliance with reporting requirements under HEERF Questioned costs: None Context: ? We were unable to identify a specific control in place to ensure that any errors would be prevented or detected in a timely manner ? The 45 day report was not submitted within the required time frame ? In the 3/31/2021 quarterly reporting, one of the seven required items was not disclosed ? In the 7/23/2020 quarterly reporting, all of the seven required items were disclosed, but we did not receive supporting documentation for one of the disclosures ? Item E (Institutional Expenditures) in the annual report was not correctly reported Cause: University staff reviewed all published guidance on reporting deadlines and interpreted the guidance to mean that the deadline for the report was slightly later than later guidance clarified it to be. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
2021-004 Higher Education Emergency Relief Fund (HEERF) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: University staff reviewed all published guidance on reporting deadlines and interpreted the guidance to mean that the deadline for the report was slightly later than later guidance clarified it to be. Action taken in response to finding: The Director of Financial Aid is responsible for all HEERF reporting and will verify deadlines against published guidance to ensure timely reporting. Name(s) of the contact person(s) responsible for corrective action: Ivette Valentin Planned completion date for corrective action plan: Corrective action plan completed prior to audit report issue date.
FAC accepted this audit on April 7, 2021 — management decision was due October 7, 2021.
FAC accepted this audit on October 21, 2019 — management decision was due April 21, 2020.
During our testing of the Federal Direct Student Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that the rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. This processing error is not within a computer system in the control of the University. While it is difficult to eliminate all errors, it is possible for colleges and universities to create an Enrollment Reporting Summary Report after reporting student status changes on NSLDS, which can help to detect these types of errors. The Summary Report must then be reviewed by financial aid staff and errors must be corrected manually. In addition, during our testing of 40 students, we noted three instances of late reporting of student status changes and three instances of improper student status reported. Questioned costs: None. Context: Out of 40 students tested, we noted three instances of late reporting of student status changes and three instances of improper student status reported. We also noted that 9 out of 12 monthly roster files tested yielded error reports that were not corrected and resubmitted within the required 10 days. Cause: The University?s processes and controls did not ensure that: (1) error reports were corrected and resubmitted within 10 days, and (2) student status changes were properly and timely reported to NSLDS. 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 University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. We also recommend that the University utilize the Enrollment Reporting Summary report each month to detect errors and correct them manually within 10 days. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2019 ? 001 Enrollment Reporting 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, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing of the Federal Direct Student Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that the rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. This processing error is not within a computer system in the control of the University. While it is difficult to eliminate all errors, it is possible for colleges and universities to create an Enrollment Reporting Summary Report after reporting student status changes on NSLDS, which can help to detect these types of errors. The Summary Report must then be reviewed by financial aid staff and errors must be corrected manually. In addition, during our testing of 40 students, we noted three instances of late reporting of student status changes and three instances of improper student status reported. Questioned costs: None. Context: Out of 40 students tested, we noted three instances of late reporting of student status changes and three instances of improper student status reported. We also noted that 9 out of 12 monthly roster files tested yielded error reports that were not corrected and resubmitted within the required 10 days. Cause: The University?s processes and controls did not ensure that: (1) error reports were corrected and resubmitted within 10 days, and (2) student status changes were properly and timely reported to NSLDS. 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 University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. We also recommend that the University utilize the Enrollment Reporting Summary report each month to detect errors and correct them manually within 10 days. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the last fiscal year, the University changed from three trimesters to monthly semester (session) starts. It was known that this change would require changes to reporting procedures to NSC. The reporting procedures followed were implemented under guidance from NSC staff that unfortunately proved incorrect. The University?s registrar?s office has already modified its reporting to NSC to include all monthly sessions that are currently active and will also report all enrolled credit hours for each student instead of current active credit hours. The monthly reconciliation report is being monitored and corrections are submitted to NSC manually within 10 days. Name(s) of the contact person(s) responsible for corrective action: Noah Lamb, Joshua Carcopa
It was noted during audit testing that the University did not meet the community service requirement for its Federal Work Study allocation, and did not obtain a waiver from the Department of Education releasing it from the requirement. Questioned costs: None. Context: Community service activities represented 6.4% of the University?s Federal Work Study allocation for the award year. Cause: The University did not receive a waiver from the Department of Education to waive this requirement. Effect: Based on the University?s Federal Work Study funding received for the award year, the University was $634 short of meeting the 7% community service requirement. Repeat Finding: No. Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, or contact the Department of Education to request a waiver. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Show full finding ▾Hide full finding ▴2019 ? 002 Community Service Requirement Federal agency: Department of Education Federal program: Student Financial Assistance Cluster CFDA Number: 84.033 ? Federal Work Study Program Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.18(g) require institutions to use at least 7% of the sum of its initial and supplemental Federal Work Study allocation for an award year to compensate students employed in community service activities unless a waiver is obtained from the Department of Education. Condition: It was noted during audit testing that the University did not meet the community service requirement for its Federal Work Study allocation, and did not obtain a waiver from the Department of Education releasing it from the requirement. Questioned costs: None. Context: Community service activities represented 6.4% of the University?s Federal Work Study allocation for the award year. Cause: The University did not receive a waiver from the Department of Education to waive this requirement. Effect: Based on the University?s Federal Work Study funding received for the award year, the University was $634 short of meeting the 7% community service requirement. Repeat Finding: No. Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, or contact the Department of Education to request a waiver. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan prepared by the University.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report has been created to monitor spending on the federal work study program and scheduled monthly to ensure that the institution meets the 7% threshold. Financial aid staff will also monitor off-site work study locations on a monthly basis for retention purposes to ensure that at least two to three work study students are placed in community service positions at all times. Name(s) of the contact person(s) responsible for corrective action: Noah Lamb Planned completion date for corrective action plan: completed prior to audit report issue date
FAC accepted this audit on October 22, 2018 — management decision was due April 22, 2019.
FAC accepted this audit on September 4, 2017 — management decision was due March 4, 2018.
FAC accepted this audit on December 5, 2016 — management decision was due June 5, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-005
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
