Tusculum University

2025-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001, 2023-003, and 2024-005) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 8 indicating an error rate of 20.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: Tusculum University acknowledges this finding. The university has identified the issue that is occurring that is causing the enrollment to be reported incorrectly. We are currently working with the IT Department to fix the error that is occurring within the system itself. In the meantime, students who are impacted by the incorrect enrollment status reporting are being manually fixed in the system and then the record is being pulled and reported to clearinghouse. Overall, the university has been working to reduce the number of incorrect enrollment status reportings. This can be seen by the fact that we went from a 45% error rate in 2023-24 to a 20% error rate in 2024-25. Finally, the Registrar’s Office shall be main office reporting clearinghouse data in the future, with financial aid only acting as a secondary reporter should the Registrar’s Office not be available to report.

2024-001 Significant Deficiency: TEACH Grant Sequester Miscalculation (U.S. Department of Education, Teacher Education Assistance for College and Higher Education Grants, ALN #84.379) Criteria: In accordance with the Electric Announcement General 23-37 and the Budget Control Act of 2011, the statutory award amount for all TEACH Grant awards where the first disbursement is on or after Oct. 1, 2020, and before Oct. 1, 2024, must be reduced by 5.70%. Statement of Condition: During the 2024 audit, it was noted that the University miscalculated the sequester for a student, resulting in an under-award. Questioned Costs: This finding is monetary in nature. In the instance noted in testing, the total error is $36 in under-award. Extrapolation of this monetary error estimates a total potential error of $63. This does not exceed the $25,000 reporting threshold for monetary error within Federal Award Programs. Perspective Information: The audit included a detailed testing of 1 file for students who had received TEACH, so the identification of this error in the student’s file review results in an error rate of 100%. This does exceed the reporting threshold of 10% for Federal Award Programs. Cause and Effect: Due to oversight by the financial aid counselor awarding a student’s TEACH grant, a student received fewer TEACH grant dollars than those for which they were eligible. Recommendation: The University should ensure that sequester fees are appropriately calculated and that amounts disbursed to students are in line with the regulations. The director of financial aid should provide a review check on such calculations. View of Responsible Officials: The University acknowledges this finding. The error occurred when entering the TEACH Grant into Colleague. Instead of awarding $1886 for both fall and spring, the last two digits were transposed and thus $1868 was entered for fall and spring creating the $36 under-award for the year. Financial Aid has instituted a new practice that all TEACH Grant awards are double checked when awarded and before the start of each term to make sure that the correct amount was awarded and that an entry error does not occur again.

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Criteria: In accordance with 34 CFR 675.24, an institution shall compute FWS compensation on an hourly wage basis for actual time on the job. An institution may not pay a student a salary, commission, or fee. The minimum wage rate for a student employee under the FWS program is the minimum wage rate required under section 6(a) of the Fair Labor Standards Act of 1938. The Fair Labor Standards Act of 1938, as amended, prohibits employers (including schools) from accepting voluntary services from any paid employee. Any student employed under FWS must be paid for all hours worked. Statement of Condition: During the 2024 audit, it was noted that the University did not fully compensate students for hours worked. Questioned Costs: This finding is monetary in nature. In the instances noted in testing, the total error is $47 in under-award. Extrapolation of this monetary error estimates a total potential error of $1,717. This does not exceed the $25,000 reporting threshold for monetary error within Federal Award Programs. Perspective Information: The audit included a detailed testing of 5 files for undergraduate students who had received Federal Work-Study funds for hours worked, of which this error applies to 2, indicating an error rate of 40.0%. This does exceed the reporting threshold of 10% for Federal Award Programs. Cause and Effect: This issue is the result of oversight during payroll processing. Errantly miscalculating hours worked and wages payable results in students receiving fewer Title IV funds than what they may have earned or be eligible for. Recommendation: The University should institute checks within their payroll process specific to ensuring appropriate amounts are paid to recipients of Federal Work-Study funds. View of Responsible Officials: The University acknowledges this finding. Upon discovery of this error, the students were paid the hours that had been missed. To ensure this error does not occur again in the future, financial aid has created a secondary check system that includes keeping an additional excel that confirms that each timesheet has been paid for each student and that their full hours worked have been paid. We have also reinforced with supervisors the urgency of making sure that timesheets are submitted in a timely manner so that this error does not occur again. Additional training for supervisors will also occur.

2024-003 Significant Deficiency: Federal Work-Study (FWS) (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Criteria: Per the Federal Student Aid Handbook, in general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Statement of Condition: During the 2024 audit, students were identified to have received Federal Work-Study funds for hours submitted that coincided with scheduled class time without an acceptable exception. Questioned Costs: This finding is monetary in nature. In the instances noted in testing, the total error is $30 in over-award. Extrapolation of this monetary error estimates a total potential error of $1,096. This does not exceed the $25,000 reporting threshold for monetary error within Federal Award Programs. Perspective Information: The audit included a detailed testing of 5 files for undergraduate students who had received Federal Work-Study funds for hours worked, of which this error applies to 2, indicating an error rate of 40.00%. This does exceed the reporting threshold of 10% for Federal Award Programs. Cause and Effect: This issue is the result of oversight during payroll processing. By failing to compare hours submitted as worked hours to student class schedules, students have been over-paid Federal Work-Study funds. Recommendation: The University should incorporate a step into the payroll process for students that would compare submitted hours to the students’ class schedules. View of Responsible Officials: The University acknowledges this finding. In order to ensure that this does not occur again, all supervisors have been reminded of the requirement that students do not work during seat time. Regular reminders to supervisors go out about Federal Work Study Guidelines. In addition, as each timesheet is submitted, financial aid shall check to ensure no violations have occurred. Additional training for supervisors will also occur.

2024-004 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-002) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. A new policy was put into place during June 2024. The seven required elements for the GLBA policy are as follows, along with the status within each of the University’s policies in place during the year: 1. The policy designates a qualified individual responsible for overseeing and implementing the institution’s information security program and enforcing the information security program in compliance. This attribute was not addressed in the existing policy; the newly implemented policy does sufficiently address this requirement. The director of information systems, Casey Reagan, has been identified as the responsible party. 2. The policy provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution) that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. This attribute was not addressed in the existing policy; the newly implemented policy does sufficiently address this requirement. The University contracted with a third-party cybersecurity firm to address this requirement in the updated policy. 3. The policy provides for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), which are detailed as follows: 3.1. Implement and periodically review access controls. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 3.2. Conduct a periodic inventory of data, noting where it is collected, stored or transmitted. Both the existing policy and the newly implemented policy are silent on this requirement. 3.3. Encrypt customer information on the institution’s system and when it is in transit. Both the existing policy and the newly implemented policy are silent on this requirement. 3.4. Assess applications developed by the institution. Both the existing policy and the newly implemented policy are silent on this requirement. 3.5. Implement multi-factor authentication for anyone accessing customer information on the institution’s system. Both the existing policy and the newly implemented policy are silent on this requirement. 3.6. Dispose of customer information securely. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 3.7. Anticipate and evaluate changes to the information system or network. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 3.8. Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 4. The policy provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. This attribute was not addressed in the existing policy; the newly implemented policy does sufficiently address this requirement. The University contracted with a third-party cybersecurity firm to address this requirement in the updated policy. 5. The policy provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 6. The policy addresses how the institution will oversee its information system service providers. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 7. The policy provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the institution’s information security program. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2024 audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: During the current year, the responsible parties began putting procedures into place and drafted an updated policy to ensure deficiencies in the information security policy are addressed. As this process requires the coordination of multiple individuals, software systems, and approvals, the updates were unable to be completed by June 30, 2024. Recommendation: The University should continue to update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively and timely. View of Responsible Officials: The University acknowledges this finding. The University was in the process of updating this policy in 2023-24 to be in compliant and has finished updating the policy. The FSA Cyber Compliance Team reached out to Tusculum due to this finding for the 2022-23 audit period and Tusculum provided the Corrective Action Plan and new policy. On August 1st, 2024, Tusculum received word that the CAP acceptably addressed the GLBA finding. For the issues that are above that list that our policy is silent on the issue, the University will further detail our policy on the measures enacted.

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 18, indicating an error rate of 45.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University acknowledges this finding. While the university did implement changes from the prior year, including randomly sampling students, after this finding and looking into the issue that was occurring, we found three more issues with our clearinghouse data. The first issue was our graduation file that was sent to clearinghouse was not being processed and being rejected. We were unaware of the rejection of the records. We are currently still working with clearinghouse to find what is causing the graduation file to reject and are working on getting that corrected. The second issue was that some student files were individually being rejected and thus not processing fully through. To correct this issue, we are watching the rejected clearinghouse files for individual students and are manually reporting their statuses if we cannot get the file to accept. The final and third issue was that students who were unofficially or administratively withdrawn were pulling the wrong date and thus the status was showing the wrong dates for the occurrence. To fix this, financial aid and the registrar are working in tandem to ensure that the correct date that the actual unofficial withdrawal or administrative withdrawal is correct. If necessary, we will manually certify these students as well.

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: Due to oversight by the director of the program, the GLBA policy was not reviewed and updated for changes to the program as required by the Compliance Supplement. Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively. View of Responsible Officials: The University concurs with this finding. The University has begun the process of updating policies and procedures to comply with all of the latest GLBA policies. The university is currently in the process of finishing the risk assessment and will update all applicable policies and procedures to align with the GLBA requirements.

2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 12, indicating an error rate of 30.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Student enrollment status is pulled monthly into a report and submitted to clearinghouse out of Colleague. The failure of the system to pull the correct enrollment status for changes in enrollment is noted and the Director of Financial Aid and the Registrar of the university will work in conjecture to determine why the report that pulls out of the system is not pulling accurate student enrollment status for changes in enrollment. Once fixed, we will continue to monitor by pulling a list of random sampling of students out of each monthly report to ensure that enrollment status is being reported correctly.

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. It has been determined that where Anthology reported enrollment based off of programs version instead student types that the export to Clearinghouse did not pull correctly for every student because of multiple program versions that a student could have active. The institution has resolved this issue with the conversion back to Colleague which pulls student types.

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Statement of Condition: During the audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 11, indicating an error rate of 27.50%. Cause and Effect: Due to employee turnover and lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: The University concurs with this finding. Due to changeover in staffing and transition of systems, the data and personnel were limited to uploading the documentation in a timely manner. Now that majority of transition has occurred back to colleague, the system conversion should no longer be an issue as of this point forward. As for staffing personnel, the Director of Financial Aid shall upload the data to clearinghouse. Any further transition, and the Associate Director of Financial Aid shall immediately assume the responsibility of uploading the data upon notice of changeover of personnel.

2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 668.22(c) a student's withdrawal date is: (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification, the mid-point of the payment period; (4) if the institution determines that a student did not begin the institution's withdrawal process or otherwise provide official notification to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student's control, the date that the institution determines is related to that circumstance; (5) If a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if a student takes a leave of absence that does not meet certain requirements, the date that the student began the leave of absence. Statement of Condition: During the audit, it was noted that the University reported the incorrect date to NSLDS for the withdrawal date. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 8, indicating an error rate of 20.00%. Cause and Effect: Due to lapses in communication between departments and misunderstanding of the guidance for NSLDS reporting, the University reported the incorrect withdrawal date in some instances, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal date is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Despite the withdrawal date being placed in Anthology, the status date that the withdrawal date was input was sent to clearinghouse instead of the true withdrawal date. Tusculum University has since switched back to Colleague which submit the true withdrawal date when exporting the data to upload to clearinghouse.

2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(c), if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the withdrawal date to be used for calculation of return to Title IV may be the mid-point of the payment period or a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity. An institution must document a student's withdrawal date determined in accordance with this guidance and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. Questioned Costs: Such information is not applicable for this finding since it did not result in a monetary error. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 9, indicating an error rate of 22.50%. Cause and Effect: The University transitioned tracking and reporting software multiple times during the 2022 year. Through these transitions, information submitted for unofficial withdrawals of students was lost and could not be obtained at the time of testing. No other supporting documentation was available to verify the reasonableness of dates used in calculating the return to Title IV funds. In the case that invalid dates had been used in this calculation, there could be resulting monetary errors. Recommendation: The University should ensure that information received and utilized in the withdrawal process is sufficient and retained. View of Responsible Officials: The University concurs with this finding. Due to system conversions, the ability to produce data was limited. Now that the institution is back in Colleague, the institution will be able to properly provide proper documentation for unofficial withdrawals. To properly document unofficial withdrawals, the professor/registrar will input the last date of attendance into the system at the same time that they input the grade for the course. Financial aid will then regularly run the RGER report out of Colleague which provides the last date of attendance along with the letter grade. Using the RGER Report, the financial aid office will then perform the R2T4 and will subsequently print the RGER report for the student to add to the R2T4. If any questions should arise when notified of an unofficial withdrawal, financial aid will reach out to academic advisor/professors for clarification.

2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $55 over-awarded. Extrapolation did not result in an estimated monetary error in excess of the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For withdrawal calculations performed in the spring semester, the total day count was not performed per the instructions described in the Student Financial Aid Handbook. The use of an incorrect total number of calendar days will result in a miscalculation of percentage of Title IV aid earned and may additionally result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University concurs with this finding. The R2T4 calendar will now be a two-step process in which the Director of Financial Aid drafts the calendar and then the Associate Director of Financial Aid reviews the calendar each semester for accuracy. Furthermore, during the R2T4 process, the Director of Financial Aid shall perform the first calculation. Then, the Associate Director of Financial Aid shall review the calculation. Both will calculate the R2T4 independently of each other to ensure that the calculation is correct. Then, after the Associate Director has independently calculated the R2T4, the Associate Director shall check her calculation against the Director of Financial Aid?s calculation. Once the accuracy of the R2T4 has been confirmed, the Associate Director shall process the changes to the student?s account.

2021-001 Material Weakness: Direct Subsidized Loans were Not Awarded before Direct Unsubsidized Loans (U.S Department of Education, William D. Ford Federal Direct Loan Program, ALN #84.268) Criteria: In accordance with 34 CFR 685.200(a)(iii), a student may not receive a Direct Unsubsidized Loan unless the student has received a Direct Subsidized Loan for the maximum amount for which the student is eligible. Statement of Condition: During the audit, it was noted that the University awarded one student a Direct Unsubsidized Loan before awarding the student a Direct Subsidized Loan. Questioned Costs: The known monetary error was $1,328, which resulted in an extrapolated error of $113,342. Perspective Information: The audit included a detailed testing of 40 student files, of which this material weakness applies to 1, indicating an error rate of 2.50%. Cause and Effect: This issue was caused by an oversight in the type of loan that was awarded to the students. The effect is that one student was under-awarded Direct Subsidized Loans and over-awarded Direct Unsubsidized Loans. Recommendation: The University should ensure that students are awarded the maximum amount of Direct Subsidized Loans before being awarded Direct Unsubsidized Loans. View of Responsible Officials: The University concurs with this finding. It has been determined that an incorrect EFC value in the awarding worksheet caused by human data entry error caused the miscalculation of need.

2021-002 Material Weakness: Federal Pell Grant not Calculated Correctly (U.S. Department of Education, Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 690.63, a student?s Federal Pell Grant award is to be calculated based on the Pell Grant payment schedule and is dependent on the student?s enrollment status. Statement of Condition: During the audit, it was noted that the University incorrectly calculated the Federal Pell Grant payment for two students. Questioned Costs: The known monetary error was $1,318, which resulted in an extrapolated error of $48,297. Perspective Information: The audit included a detailed testing of 40 student files, of which this material weakness applies to 2, indicating an error rate of 5.00%. Cause and Effect: This issue was caused by an oversight in the calculation of the Federal Pell Grant payment. The effect is that one student was under-awarded and another student was over-awarded the Federal Pell Grant. Recommendation: The University should ensure that students are awarded the correct Federal Pell Grant amount, based on the Pell Grant payment schedule and the student?s enrollment status. View of Responsible Officials: The University concurs with this finding. In prior rules for 150% Pell awarding, it was a requirement that students complete 100% of scheduled awards prior to tapping into the other 50%. This rule changed in the 2nd round of 150% awarding, and this procedure was carried forward by mistake. This has been corrected.

2020-001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period or period of enrollment completed, the total number of calendar days in a payment or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period or period of enrollment completed. Questioned Costs: Such information is not applicable for this finding, due to the fact that it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 5, indicating an error rate of 12.50%. Cause and Effect: This issue was caused by errors in the counting of the total number of calendar days in the payment period or period of enrollment. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment is counted correctly. View of Responsible Officials: The University concurs with this finding. It has been determined that Colleague was incorrectly setup with closed dates for the semester. The R2T4 calendar will now be a two step process in which one person sets up Colleague and the Director of Financial Aid will review each semester prior to the completion of an R2T4.

2019-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268 and Federal Pell Grant Program, CFDA #84.063) (original finding number 2017-001) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student status changes for students who received Direct Loan and Pell grant disbursements. Questioned Costs: Such information is not applicable for this finding, due to the fact that it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 12, indicating an error rate of 30.00%. Cause and Effect: This issue was caused by reporting errors not being handled in a timely manner. Recommendation: The University should ensure that the appropriate data is submitted to the NSLDS in order to ensure correct student status reporting. View of Responsible Officials: The University administration concurs with this finding. It was determined in the Corrective Action Plan last year that the Financial Aid Director would perform random monthly audits to ensure compliance reporting. During the September, October and November monthly audits, findings were in fact found and addressed. The Financial Aid Director assisted in correcting errors with the December submission. However, this reporting was not handled in timely manner. The Office of Financial Aid and specifically the Financial Aid Director became responsible for all enrollment reporting to Clearinghouse in January 2019.

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