Cameron University

Criteria or Specific Requirement ? Return of Title IV Funds ? 34 CFR ?668.22 Condition ? The University did not review 18 of 26 R2T4 calculations tested. Questioned Costs ? None Context ? Out of a population of 174 students, 26 students were selected for testing. Of those student R2T4 calculations, 18 did not have evidence of review. Our sample was not, and was not intended to be, statistically valid. Effect ? The University could have incorrect R2T4 calculations, though none were noted in our testing. Cause ? The University did not have controls operating effectively to review the R2T4 calculations. Identification as a Repeat Finding, if Applicable ? N/A Recommendation ? The University should ensure the operating effectiveness of manual controls specific to the R2T4 calculation process to ensure that all R2T4 calculations are reviewed prior to returning funds. For manual controls, the University should ensure that the Director of Student Aid is reviewing the calculations. Views of Responsible Officials and Planned Corrective Actions ? This requirement had been overlooked due to a change in personnel in Student Financial Services. The Director of Student Financial Services has established the proper procedures regarding the R2T4 calculations and is now reviewing and approving each R2T4 calculation.

2020-002: Enrollment Reporting NSLDS Federal agency: U.S. Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007, 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: 34 CFR 685.309 (b) - Enrollment Reporting - Unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who?(i) Enrolled at that school but has ceased to be enrolled on at least a halftime basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period for which the loan was intended; or (iii) Has changed his or her permanent address. Condition: During our testing, we noted for two of the 40 students tested that change in status were not reported timely. We also noted three of the 40 students tested were not correctly reported to NSLDS. Lastly, we noted for two of the 40 students tested that enrollment was not cerifitied every 60 days. Questioned Costs: None Cause: The University?s processes and controls did not ensure that 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: Yes, Prior year finding 2019-001 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. Management Response: Student Financial Services updated its policies and procedures regarding Enrollment Reporting in collaboration with the Registrar?s office. The Assistant Registrar has been given access to NSLDS so review can occur regularly after submission to the National Student Clearinghouse. SFS also implemented a process where a standard 15 day SCHER report is provided to the Assistant Registrar. In addition, the Director of Student Financial Services, the Information Systems Specialist and the Assistant Registrar meet monthly to discuss errors and updates and to work collaboratively to ensure that all errors are corrected accurately and within the required timeframe.

2020-003: Common Origination and Disbursement Federal agency: U.S. Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Award Period: July 1, 2019 to June 30, 2020 Criteria or Specific Requirement: OMB No. 1845-0021 ? Institutions must report all loan disbursements and submit required records to Common Origination and Disbursement (COD) within 15 days of disbursement. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Condition: During our testing, we noted two of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and disbursement (COD) system. In addition, two of 40 disbursments tested were not reported within 15 days of disbursement. Lastly, one of the 40 disbursements tested was not reported in COD. Cause: The student?s disbursement was rejected by COD and university staff was not monitoring the COD rejection report and therefore it was not corrected until several months later. Questioned Costs: None Effect: Disbursements were not correctly reported to COD. Repeat Finding: Yes, Prior year finding 2019-002 Recommendation: The University should monitor rejections from COD to ensure that the disbursement dates for students who received Federal Pell Grants and Direct Loans are accurate. Any discrepancies should be updated in COD to reflect the actual disbursement date. Management Response: Student Financial Services will monitor rejections from COD to ensure corrections are made both accurately and timely.

2020-004: Gramm-Leach-Bliley Act ? Student Information Security Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Context: During our audit procedures, it was noted that the University did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: University management has an IT department, however, the University should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: University has a detailed action plan to become compliant with the requirements of the Gramm-Leach-Bliley Act by May 1, 2021.

2020-005: Return of Title IV Calculation Errors Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: An institution that is not required to take attendance may use as the withdrawal date, the last date of attendance at an academically related activity as documented by the institution (34 CFR668.22(c) and (d)). In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Condition: During our testing we noted one of the 16 students tested who?s withdrawal date used to calculate the Return of Title IV Funds was during the scheduled spring break, when no academically related activities were in process. Additionally, during our testing we noted the University did not investigate students who withdrew prior to the add/drop period to determine if students began attendance during the payment period and earned post-withdrawal financial aid. Questioned Costs: None Cause: The University does not have procedures in place to ensure student awards are properly adjusted based on calculations performed. Effect: The University is not returning the proper amounts to the Department based on the calculations performed. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student?s account and the correct amounts are being returned to the Department. Management Response: The Director of Student Financial Services is now reviewing and approving each R2T4 calculation as of August 2020.

2020-006: Reconciliations of the Direct Loan Program Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary. Condition: Direct loan reconciliations between the COD, G5 and student accounts were not being performed for the year. Questioned Costs: None Cause: The University?s management did not have procedures in place to ensure reconciliations were performed in a timely maner. Effect: University is not complying with internal policy and federal requirements to ensure funds are properly reconciled. Repeat Finding: No Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University?s policies and federal requirements related to monthly reconciliations. Management Response: This requirement had been overlooked due to a change in personnel. The reconciliations are now being performed on a monthly basis and are reviewed and approved by the Director of Student Financial Services as of August 2020.

2019-001: Enrollment Reporting NSLDS (Significant Deficiency/No Questions Costs) Federal Program: Title: Student Financial Assistance Cluster Award Period: July 1, 2018 to June 30, 2019 Criteria or Specific Requirement: 34 CFR 685.309 (b) - Enrollment Reporting - Unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who?(i) Enrolled at that school but has ceased to be enrolled on at least a halftime basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period for which the loan was intended; or (iii) Has changed his or her permanent address. Condition: During the year, several student status changes were not properly reported to NSLDS within the 30-day timeframe. Cause: The University?s processes and controls did not ensure that 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. Management Response: Student Financial Services will update its policies and procedures regarding Enrollment Reporting in collaboration with the Registrar's office no later than November 1, 2019. The Assistant Registrar will also be given access to NSLDS so review can occur regularly after submission to the National Student Clearinghouse. SFS will also implement a standard 15 day SCHER report pull to be provided to the Assistant Registrar. In addition, the Director of Student Financial Services, the Information Systems Specialist and the Assistant Registrar will meet monthly to discuss errors and updates and to work collaboratively to ensure every effort will be given so that all errors are corrected accurately and within the required timeframe.

2019-002: Borrower Data ? Direct Loans (Significant Deficiency / No Questioned Costs) Federal Program: Title: Student Financial Assistance Cluster Award Period: July 1, 2018 to June 30, 2019 Criteria or Specific Requirement: OMB No. 1845-0021 ? Institutions must report all loan disbursements and submit required records to Common Origination and Disbursement (COD) within 15 days of disbursement. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Condition: During our testing, we noted one loan disbursement was reported to COD before being applied to the student?s account. Cause: The student?s disbursement was rejected by COD and university staff was not monitoring the COD rejection report and therefore it was not corrected until several months later. As a result, the disbursement was not accepted before or on the date of the actual disbursement and reverted back to the original scheduled disbursement date which was the day before the actual disbursement occurred. Effect: Disbursements were not correctly reported to COD. Repeat Finding: No Recommendation: The University should monitor rejections from COD to ensure that the disbursement dates for students who received Federal Pell Grants and Direct Loans are accurate. Any discrepancies should be updated in COD to reflect the actual disbursement date. Management Response: Student Financial Services will monitor rejections from COD to ensure corrections are made both accurately and timely.

2019-003: Student Awards (Significant Deficiency/No questioned costs) Federal Program: Student Financial Aid Cluster Award Period: All Grant Years Criteria or Specific Requirement: 34 CFR 685.301- awards must be coordinated among the various programs and with other Federal and nonFederal aid (need and nonneed based aid) to ensure that total aid is not awarded in excess of the student?s financial need. Further, the determination of SFA award amounts is based on financial need. Financial need is generally defined as the student?s Cost of Attendance (COA) minus financial resources reasonably available. For Title IV programs, the financial resources available is generally the Expected Family Contribution (EFC) that is computed by the central processor and included on the student?s SAR and the ISIR provided to the institution. Condition: It was noted that the University relies on Banner to calculate student?s COA and student?s need. During our audit procedures, it was noted that the summer portion for several students was not included in the COA in the Banner system used to calculate the student?s need, although the student was awarded aid for the summer semester. Therefore, in Banner, the amount awarded was greater than the student?s calculated need. There was no review or approval of the override of the student?s award documented. Cause: Controls in the Banner system, which the University relies on to calculate student awards, allows for SFA Counselors the ability to override the student award calculated by Banner. Effect: The potential exists that students are over awarded. Repeat Finding: No Recommendation: The University should review processes and procedures to ensure that all student awarded are reviewed by an appropriate financial aid advisor or counselor if manual adjustments are made. All approvals should be documented and maintained. Management Response: Student Financial Services will work with Information Technology Services to help create standard reports that will identify students who may be over awarded or exceed their Cost of Attendance. The review during the packaging process will be evaluated to determine if additional reports are needed to help identify errors. The packaging process itself will be evaluated to ensure accuracy of the awarding process to reduce the need for manual adjustments. The Cost of Attendance will be reviewed and approved by the Vice President for Business and Finance before SFS will update for the next academic year. This process will be documented and maintained for each academic year.

2019-004: Eligibility (Significant Deficiency/No Questioned Costs) Federal Program: TRIO Cluster ? Upward Bound Award Period: All Grant Years Criteria or Specific Requirement: 34 CFR 645.3 and 645.6 - an individual is eligible to participate in a Regular, Veterans, or Math-Science UB project if the individual meets all of the following requirements: (a) is a citizen, national, or permanent resident of the United States, or is in the United States for other than a temporary purpose; (b) is a potential first-generation college student, a low-income individual, or an individual who has a high risk for academic failure; (c) has a need for academic support in order to pursue successfully a program of education beyond high school; and (d) at the time of initial selection has completed the 8th grade but has not entered the 12th grade and is at least 13 years old but not older than 19. A veteran, regardless of age, who meets all other criteria is eligible to participate. Condition: During our testing, one of the program participants selected for testing was missing the appropriate approval prior to actively participating in the program activities. Cause: The University?s internal controls did not ensure all program participants were properly reviewed and approved prior to participating in program activities. Effect: The potential exists that services are provided to ineligible students. Repeat Finding: No Recommendation: The University should review processes and procedures to ensure that all eligibility requirements are reviewed by an appropriate federal programs advisor. All approvals should be documented and maintained. Management Response: The University will review processes and procedures to ensure that all eligibility requirements are reviewed by Upward Bound Director. All approvals will be documented and maintained.