EIN: 710239576
UEI: E8JMLPBES6E6
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 2, 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 April 2, 2025 (510 days ago).
What is a management decision? →When students withdrew either officially or unofficially from modular programs, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 20 students tested for timely and accurate R2T4’s, 1 student in a modular program had their unearned Title IV aid totaling $2,242 returned 7 days late. The University reviewed all modular student withdrawals and identified 2 other students with late returns in the amounts of $2,292 and $675, 91 to 345 days late, respectively. Cause: As part of the financial aid office’s internal review process, the 3 students were identified as needing returns and the returns were done promptly. However, the notification of on-line, modular students ceasing attendance was not communicated timely to the financial aid office causing the returns to be late. Effect: Noncompliance with R2T4 regulations regarding timely returns and withdrawals from modular programs. Identification as repeat finding, if applicable: Yes, 2023-001 Recommendation: We recommend that the University continue to work with the registrar’s office to provide timely and accurate dates of last attendance so that return of Title IV funds can be completed within the timeframe required by the Department of Education. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely Returns of Title IV Funds (R2T4) DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially from modular programs, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 20 students tested for timely and accurate R2T4’s, 1 student in a modular program had their unearned Title IV aid totaling $2,242 returned 7 days late. The University reviewed all modular student withdrawals and identified 2 other students with late returns in the amounts of $2,292 and $675, 91 to 345 days late, respectively. Cause: As part of the financial aid office’s internal review process, the 3 students were identified as needing returns and the returns were done promptly. However, the notification of on-line, modular students ceasing attendance was not communicated timely to the financial aid office causing the returns to be late. Effect: Noncompliance with R2T4 regulations regarding timely returns and withdrawals from modular programs. Identification as repeat finding, if applicable: Yes, 2023-001 Recommendation: We recommend that the University continue to work with the registrar’s office to provide timely and accurate dates of last attendance so that return of Title IV funds can be completed within the timeframe required by the Department of Education. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: In addition to the Withdrawal Tracker created last year to document the withdrawal process and communicate across the department, the SFS team will now also pull official withdrawal lists (including unofficial withdrawals) every semester with assistance from the Director of Institutional Research and Assessment –Lynette Duncan. We will also work with her to create a report which will pull that data directly from Colleague SIS rather than relying on communication from the registrar’s office or professor. We have several new arrangements that will improve our R2T4 processes and ensure accuracy. Firstly, the registrar’s office has created a new automated withdrawal form detailing all elements pertaining to LDA dates that will produce automated email notifications to our office. This form will pull data from BlackBoard listing the last interaction date the student had with the BB system. This will encourage our tracking processes to run more swiftly. In addition, we will still track each withdrawal in real time on the SFS Withdrawal Tracker, but the information will be cross-referenced against the system generated withdrawal data from the Director of Institutional Research and Assessment to ensure precision and compliance. After the Director of Student Financial Services processes an R2T4 calculation, the Chief Student Finance Officer will review the work to ensure accuracy on a weekly basis. Finally, we will move the R2T4 process into Colleague rather than doing this process on the COD website. This will add another layer of checks and balances for correct data and greatly increase the speed with which the Director of Student Financial Services can perform R2T4s. Person Responsible for Corrective Action Plan: Michelle Baker McFadden, Director of Student Financial Services Anticipated Date of Completion: Implementation of process will begin 9/30/2024
2023-001
The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 76 students tested for proper NSLDS enrollment status, 1 student who officially withdrew in the spring of 2024 was still being reported as full time. 1 student was reported as “no records found” but has federal direct loan borrowing at the University. 1 student withdrew in 2023 but was not reported as re-enrolled in 2024 even though the student attended 3 terms in the year before withdrawing again. Cause: System errors Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure the appropriate fields are captured from the system for NSLDS enrollment reporting. We also recommend spot checking students who withdraw officially or unofficially to ensure that they are reported timely and accurately. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 76 students tested for proper NSLDS enrollment status, 1 student who officially withdrew in the spring of 2024 was still being reported as full time. 1 student was reported as “no records found” but has federal direct loan borrowing at the University. 1 student withdrew in 2023 but was not reported as re-enrolled in 2024 even though the student attended 3 terms in the year before withdrawing again. Cause: System errors Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure the appropriate fields are captured from the system for NSLDS enrollment reporting. We also recommend spot checking students who withdraw officially or unofficially to ensure that they are reported timely and accurately. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and implemented by Student Financial Services. For official withdrawals, an additional processing step will be added to the SFS Withdrawal Tracker. The Student Financial Services rep will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. For unofficial withdrawals, if a student is identified as an unofficial withdrawal (e.g. lack of attendance in a course resulting in an R2T4 calculation being performed) once the withdrawal list has been reported at the end of each semester by the Registrar’s office, the Student Financial Services Representative will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implementation of process will begin 9/30/2024
FAC accepted this audit on October 30, 2023 — management decision was due April 30, 2024.
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $44 Context: 3 of 10 withdrawals tested were not returned timely totaling $7,676 and ranging from 6 to 178 days late. Of those, 1 student did not have the correct amount returned, resulting in a $44 under-return of federal direct loans. Additionally, out of the 10 withdraws tested, 1 student had a calculation error in the R2T4 form and had $147 more in federal direct loans returned than required. This was due to an inaccurate tuition amount used in the calculation. Cause: This was an oversight by the University. Effect: Incorrect amounts of federal funding were returned, and funds were not returned timely. Identification as repeat finding, if applicable: n/a Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review student's R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $44 Context: 3 of 10 withdrawals tested were not returned timely totaling $7,676 and ranging from 6 to 178 days late. Of those, 1 student did not have the correct amount returned, resulting in a $44 under-return of federal direct loans. Additionally, out of the 10 withdraws tested, 1 student had a calculation error in the R2T4 form and had $147 more in federal direct loans returned than required. This was due to an inaccurate tuition amount used in the calculation. Cause: This was an oversight by the University. Effect: Incorrect amounts of federal funding were returned, and funds were not returned timely. Identification as repeat finding, if applicable: n/a Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review student's R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: A new administrative withdrawal procedure has been created to ensure that Title IV is both timely and accurately returned to the Federal Government in the case of an official / unofficial withdrawal from the university. A shared Office365 document was created to track the number of days in each segment of the withdrawal process. The Student Financial Services (SFS) Representative initiates the process upon notification of withdrawal from the Registrar. Appropriate documentation is gathered at the time of withdrawal to establish the correct timeline for the potential return of Title IV funds. The SFS Representative then determines if an R2T4 calculation is required. If an R2T4 calculation is required, the SFS Representative will assign the task to the Student Loan Processor or the Director of Student Financial Services. The Student Loan Processor and Director of Student Financial Services will use Microsoft Outlook, as prompted by the shared Office365 document, to assign “due dates” for both the R2T4 calculation as well as the return of funds to COD to ensure compliance. The Director of Student Financial Services and the Chief Student Finance Officer will perform a weekly review of the shared Office365 document to confirm the accuracy of R2T4 calculations and the required timeline of the return of Title IV funds. A secondary review by a financial aid representative with the appropriate level of experience will ensure that internal controls over such processes can operate effectively and achieve compliance. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implemented August 21, 2023
The University has gaps in two areas with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not implemented multi-factor authentication on one system containing non-financial personally identifiable information (PII). Additionally, the written annual report to the board does not include all the required areas based on the updated regulations. Cause: The University has made significant progress on GLBA and has a couple of components to be in full compliance with the updated requirements of GLBA. University personnel were unaware of the system’s ability to support MFA. Effect: The University may have unintended exposure of non-financial student information to security risks. Identification as repeat finding, if applicable: n/a Recommendation: We recommend the University implement the remaining components of the revised regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Other Matter DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038 and 84.379; Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University has gaps in two areas with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not implemented multi-factor authentication on one system containing non-financial personally identifiable information (PII). Additionally, the written annual report to the board does not include all the required areas based on the updated regulations. Cause: The University has made significant progress on GLBA and has a couple of components to be in full compliance with the updated requirements of GLBA. University personnel were unaware of the system’s ability to support MFA. Effect: The University may have unintended exposure of non-financial student information to security risks. Identification as repeat finding, if applicable: n/a Recommendation: We recommend the University implement the remaining components of the revised regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The Registrar’s Office employee account used for access to the National Student Clearinghouse (NSC) website has been configured for multi-factor authentication (MFA). The board report documentation has been modified to include the required sections and will be presented as a written supplement at the fall meeting, October 6, 2023. Person Responsible for Corrective Action Plan: Paul Nast, CIO Anticipated Date of Completion: Implemented September 26, 2023
FAC accepted this audit on October 1, 2019 — management decision was due April 1, 2020.
Enrollment status was not always updated correctly to the National Student Loan Data Service (NSLDS). Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was inaccurate for 6 students out of the 71 tested. Out of the 6 exceptions, 5 of them affected repayment status. There were three separate reasons that caused the NSLDS status to be inaccurate. Three of the exceptions related to students who withdrew after the fall A module, where the National Student Clearinghouse (NSC) reported them as attending throughout the entire fall semester and the University reported them to NSC as withdrawn at the end of the fall A module. This resulted in an additional three months of deferment for these students. One student was incorrectly coded using the official notification date instead of the last date of attendance, which resulted in an extra month of deferment status. The remaining exception was an academic suspension student where financial aid was notified of the suspension but later the passing grade was changed to an F and resulted in an unofficial withdrawal. All students were corrected during the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning loan repayment, appropriate interest charges, etc. Cause: There was one incorrect link in the system to the official withdrawal notification date instead of the last date of attendance. There appears to be a disconnect between what NSC considers as withdrawn and what the University is reporting to NSC as withdrawn. For the academic suspension student, because of the late changes made in the student?s file, the student was not initially picked up as withdrawn. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University work with NSC to ensure proper withdrawal reporting is occurring. We further recommend links to last date of attendance be consistently used. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 National Student Loan Data System (NSLDS) Enrollment Reporting Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2018-2019 Financial Aid Year Condition: Enrollment status was not always updated correctly to the National Student Loan Data Service (NSLDS). Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was inaccurate for 6 students out of the 71 tested. Out of the 6 exceptions, 5 of them affected repayment status. There were three separate reasons that caused the NSLDS status to be inaccurate. Three of the exceptions related to students who withdrew after the fall A module, where the National Student Clearinghouse (NSC) reported them as attending throughout the entire fall semester and the University reported them to NSC as withdrawn at the end of the fall A module. This resulted in an additional three months of deferment for these students. One student was incorrectly coded using the official notification date instead of the last date of attendance, which resulted in an extra month of deferment status. The remaining exception was an academic suspension student where financial aid was notified of the suspension but later the passing grade was changed to an F and resulted in an unofficial withdrawal. All students were corrected during the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning loan repayment, appropriate interest charges, etc. Cause: There was one incorrect link in the system to the official withdrawal notification date instead of the last date of attendance. There appears to be a disconnect between what NSC considers as withdrawn and what the University is reporting to NSC as withdrawn. For the academic suspension student, because of the late changes made in the student?s file, the student was not initially picked up as withdrawn. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University work with NSC to ensure proper withdrawal reporting is occurring. We further recommend links to last date of attendance be consistently used. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2019-001 National Student Loan Data System (NSLDS) Enrollment Reporting Planned Corrective Action: In order to resolve Finding Number 2019-001 (National Student Loan Data System Enrollment Reporting), the University has identified a process through our Student Information System (SIS) that will correctly gather the last date of attendance in order to ensure that the withdrawal date is correctly reported on the National Student Clearinghouse (NSC) enrollment report. The University plans to test the effectiveness of the identified process during the first submission of NSC withdrawal reporting. In addition to the identified process above, an oversight procedure has been implemented within the financial aid withdrawal process to verify that the correct withdrawal date has been reported to the National Student Loan Data System (NSLDS) Person Responsible for Corrective Action Plan: Registrar / Loan Processor Anticipated Date of Completion: Upon submission of the first NSC enrollment report.
FAC accepted this audit on October 4, 2016 — management decision was due April 4, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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