Concordia University Texas

Finding 2025-001: Significant Deficiency - Return of Title IV Funds Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): Various Federal Award Number: Various Federal Award Year: June 30, 2025 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds. Condition/Context: For two of five students tested in the sample, the return of Title IV (R2T4) calculations were done late. The first student withdrew in January 2025 but the R2T4 calculation was not done until May 2025. The Pell grant was not originally disbursed but was later provided to the student as a post withdrawal disbursement (PWD) in July 2025. The second student had all loans returned when they withdrew in January and the R2T4 calculation was not done until September 2025, at which time it was determined the student did attend and earned some of the loan funds however, it was too late to disburse those funds as a PWD due to the regulations. The sample was not a statistically valid sample. Cause: The University's processes and controls did not ensure that return of Title IV calculations were performed accurately or timely. The University noted personnel changes and training new staff contributed to the delays and errors. Effect: Return of Title IV fund calculations were not completed timely. This resulted in one student not being able to receive the loan funds they should have been eligible for, and the other student did not receive timely disbursement of the grant funds they were eligible. Questioned Costs: Total known questioned costs were $4,701 of Federal Direct Loan Program funds (ALN 84.268) and $206 of Pell (ALN 84.063). Likely questioned costs projected to the population of $27,400 for Federal Direct Loan Program and $1,200 for Pell. Recommendation: The University should revise its procedures and controls surrounding withdrawals and R2T4 calculations to ensure they are completed accurately and timely. Management's Response: The University agrees with the finding. The University is currently working with the IT officers to develop a more automatic process for R2T4 calculations and processing.

Finding 2025-002: Significant Deficiency - Gramm Leach Bliley Act Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): Various Federal Award Number: Various Federal Award Year: June 30, 2025 Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021, the Federal Trade Commission issued final regulations that altered the current required elements of an information security program and added several new elements. Under the regulations, institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The written information security program for institutions must address all elements that apply. The elements for the information security programs set forth in this section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and do not prescribe how they will be addressed. Condition/Context: The University did not have updated procedures and processes in place for certain required GLBA elements. Cause: The University noted that several items required are in process or only partially completed. Effect: Failure to comply with the requirements of GLBA standards put the University out of compliance with requirements and potentially at risk of compromising consumer, nonpublic personal information. Questioned Costs: Not applicable. Recommendation: It is recommended that the University update policies and procedures to ensure compliance with the GLBA regulations. Management's Response: The University agrees with the finding. The University has begun reviewing its policies with the IT department and will be developing a plan that will provide detailed updates to the policies and procedures in accordance with the regulations.

Finding 2024-001: Significant Deficiency - Title IV Credit Balances Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 7 of 25 students tested, the students’ Title IV credit balances on their accounts were held for longer than the 14-day maximum, without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization longer than the 14-day maximum. Questioned Costs: Total questioned costs were $27,834 of Federal Direct Student Loan funds (ALN 84.268). Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2025 terms and new procedures will be put in place for the Fall 2025 term.

Finding 2024-002: Significant Deficiency – Enrollment Reporting Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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 or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: For 1 of the 28, students who were tested, the incorrect withdrawal effective date was reported to NSLDS. That student's status was also not reported to NSLDS within 60 days. The sample was not a statistically valid sample. Cause: The University's processes did not ensure accurate and timely reporting to NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management's Response: Although enhanced monitoring processes were in place to ensure integrity and punctuality of data reported to the National Student Data Loan System, the University experienced challenges in timely reporting due to staff turnover. The enhanced monitoring and reporting processes have been updated and documented and the University built redundancy into the staffing model to prevent future discrepancies.

Finding 2021-001: Federal Direct Student Loan Enrollment Reporting Program: Federal Direct Loan Programs Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K202159 Federal Award Year: June 30, 2021 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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 or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For four of twenty-five students included in our sample, the enrollment status date or enrollment status was reported incorrectly on the Campus-Level Detail and/or program-level enrollment detail. The change in student status for two of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the National Student Data Loan System. Cause: The University failed to follow its procedures for reporting student status changes. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to ensure that the correct enrollment status dates and enrollment statuses are reported to the NSLDS within the required time frames. Management?s Response: Although enhanced monitoring processes were in place to ensure integrity and punctuality of data reported to the National Student Data Loan System, the University experienced challenges in timely reporting due to staff turnover. The enhanced monitoring and reporting processes have been updated and documented and the University built redundancy into the staffing model to prevent future discrepancies.

Finding 2019-002: Significant Deficiency ? Return of Title IV Funds Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Number ? P268K192266 Federal Award Year - June 30, 2019 Repeat Finding 2018-001 Criteria Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context The federal aid refunds for one of the ten students tested was not calculated correctly and resulted in the University refunding the incorrect amount to the Title IV program. The sample was not a statistically valid sample. Questioned Costs There was a total of $1,077 of Direct Loan funds that were incorrectly returned back to the Department of Education for the student tested. Cause The University did not apply the correct guidance when calculating a refund for a student enrolled in a program offered in modules. As such, the incorrect dates were used in the calculation. Effect The University was in possession of funds belonging to the federal government longer than allowed. Recommendation The University should revisit its procedures surrounding identification of students enrolled in modular programs and ensure that its procedures for processing refunds to these types of students follows the federal guidelines. Management?s Response Concordia University Texas (CTX) acknowledges and concurs with the finding and has already implemented additional training for all Student Financial Services staff. The procedures for documenting, calculating and returning federal funds as a result of the R2T4 process has been modified to provide an additional level of review. In addition, identification of students enrolled in modular programs has been redefined so that refunds of Title IV aid follows federal guidance.

Finding 2019-003: Special Tests and Provisions ? Gramm-Leach Bliley Act Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.033, 84.268, 84.063, 84.379, 84.007 Federal Award Number - Various Federal Award Year - June 30, 2019 Criteria In accordance with Title IV regulations (16 CFR 314), an Institution must protect student financial aid information by designating an individual to coordinate the information security program, perform a risk assessment that addresses (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. Condition The University has not performed a risk assessments to address (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 as required by the Gramm-Leach Bliley Act (?GLBA?). In addition, the University has not documented safeguards for identified risks. Questioned Costs Not applicable. Context Not applicable. Cause The University did not have procedures and processes in place specific to GLBA and therefore, did not document the required risk assessment or risk mitigation. Effect Failure to comply with GLBA standards may bring penalties ranging from monetary fines to restriction or loss of eligibility for Title IV funding. Recommendation The University should designate an appropriate individual responsible for coordinating the information security program. Additionally, the University should perform and document an annual risk assessment to determine the University?s specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and documented in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Management?s Response Concordia University Texas (CTX) acknowledges and concurs with the finding. CTX already has a designated individual who is responsible for coordinating the information security program. Additionally, CTX intends to perform and document an annual risk assessment to determine the University?s risks relevant to protecting personal information. Finally, CTX will document safeguards for identified risks as required by the Gramm-Leach Bliley Act.

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