University of St. Thomas

Special Tests and Provisions – Return of Title IV Funds Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Grant Program, Assistance Listing Number 84.007 Federal Supplemental Education Opportunity Grants U.S. Department of Education Program Year 2024–2025 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Return of Title IV Funds procedures in accordance with the Uniform Guidance. (34 CFR 668.22) Condition: Federal regulations provide that the University is responsible for properly calculating return of Title IV Funds. The University’s internal control system did not prevent a return from being improperly calculated. Questioned Costs: One out of the six returns was not calculated properly, resulting in the return being understated by $353. Assistance Listing Number 84.268 Federal Direct Student Loans Context: Out of a population of 54 withdrawn students requiring return of Title IV funds, a sample of six withdrawn students were selected for testing. One out of the six returns was not calculated properly, resulting in the return being understated by $353. Our sampling method was not, and was not intended to be statically valid. Effect: Failure to properly calculate return of Title IV funds may result in the University disbursing the incorrect amount of returns. Cause: The University’s processes did not ensure that return of Title IV funds were being calculated properly. Repeat Finding: 2024-002 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV calcuations, ensuring the amounts and dates utilized in the calculation forms are correct. Views of Responsible Officials: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Grant Program U.S. Department of Education Program Year 2023-2024 Type of Finding: Other Instance of Noncompliance and Significant Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Enrollment Reporting procedures in accordance with the Uniform Guidance. (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Condition: Federal regulations provide that the University is responsible for notifying the National Student Loan Data System (NSLDS) of enrollment change. NSLDS was not notified, and the University’s internal control system did not prevent or detect that the NSLDS was not notified of change. Questioned Costs: None Context: Out of a population of 661 students with enrollment changes, a sample of 25 students were selected for testing. 2 out of the 25 enrollment changes did not get reported to NSLDS. Our sampling method was not, and was not intended to be statically valid. Effect: The failure to report enrollment changes to NSLDS may result in inaccurate or delayed updates to student loan records. Cause: The University’s processes did not ensure that enrollment status changes were completed accurately and timely to NSLDS. Repeat Finding: No Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting, ensuring NSLDS receives notification of enrollment changes. Views of Responsible Officials: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Special Tests and Provisions – Return of Title IV Funds Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Grant Program U.S. Department of Education (ED) Program Year 2023-2024 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Return of Title IV Funds procedures in accordance with the Uniform Guidance. (34 CFR 668.22) Condition: Federal regulations provide that the University is responsible for returning funds to ED and student accounts within 45 days of the University becoming aware the student has withdrawn, or within 30 days for students that never began attendance. The University’s internal control system did not prevent a late disbursement of return of funds. Questioned Costs: None Context: Out of a population of 78 withdrawn students requiring return of Title IV funds, a sample of eight withdrawn students were selected for testing. One out of the eight returns were not returned to ED or the student within the 45-day period. Our sampling method was not, and was not intended to be statically valid. Effect: The University may not be able to timely detect when return of funds are required for students who withdrew. This could result in late disbursements to ED and the student accounts for Direct Loan and Pell recipients. Cause: The University’s processes did not ensure return of Title IV funds were completed timely. Repeat Finding: No Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Views of Responsible Officials: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Student Financial Assistance Cluster Federal Pell Grant Program 84.063 Federal Supplemental Education Opportunity Grant 84.007 Federal Direct Student Loans 84.268 Federal Work Study Program 84.033 Federal Perkins Loan 84.038 Teacher Education Assistance for College and Higher Education Grants 84.379 Department of Education Program Year 2018-2019 Criteria or specific requirement ? Special Tests and Provisions ? Enrollment Reporting Condition ? Upon a change in a student's enrollment status, the University is required to report enrollment information within 30 days to the National Student Loan Data Systems (NSLDS), unless a roster will be submitted within 60 days (34 CFR 674.19 and 685.309b). Questioned costs ? None Context ? Out of a population of 935 students receiving Student Financial Aid, and which had a change in status, a sample of 40 students was selected for testing. For 11 of the 40 students tested, the University did not timely notify NSLDS of changes in student statuses. Our sampling method was not, and was not intended to be, statistically valid. Effect ? Student enrollment status changes exceeded the 60-day period for student enrollment changes submitted in roster files. Cause ? The University did not submit rosters through the batch reporting process on a timely basis. Identification as a repeat finding ? 2018-001 Recommendation ? The University should consider implementing additional controls to verify that roster files are submitted successfully. Views of responsible officials and planned corrective actions ? The University will implement additional processes to monitor and verify that all changes in enrollment are transmitted within the required timeframe and in accordance with the required technical specifications. A detailed written process has been established which delineates responsibilities for identification and resolution of reporting errors such that this issue does not recur.

Student Financial Assistance Cluster Federal Pell Grant Program 84.063 Federal Supplemental Education Opportunity Grant 84.007 Federal Direct Student Loans 84.268 Federal Work Study Program 84.033 Federal Perkins Loan 84.038 Teacher Education Assistance for College and Higher Education Grants 84.379 Department of Education Program Year 2018-2019 Criteria or specific requirement ? Special Tests and Provisions ? Gramm-Leach-Bliley Act-Securing Student Information Condition ? The University began performing their risk assessment and necessary documentation as required by the GLBA Act prior to the June 30, 2019, fiscal year end; however, the risk assessment including designating an individual to coordinate the information security program, and performing a risk assessment that addresses the three required areas noted in 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 safeguards was not fully implemented as of June 30, 2019. Questioned costs ? None Context ? University did not fully comply with the requirements under the Gramm-Leach-Bliley Act as of June 30, 2019. Effect ? Risk assessment not performed and appropriate safeguards not fully documented as of June 30, 2019. Cause ? The University began documenting the risk assessment, safeguards and related responsibilities prior to June 30, 2019, but the assessment as not complete as of June 30, 2019. Identification of repeat finding ? N/A Recommendation ? The University should complete and fully document the risk assessment, safeguards and individual responsibilities to coordinate the information security program as required by GLBA. Views of responsible officials and planned corrective actions ? The University has continued to enhance its procedures, assessments and delineation of responsibilities related to GLBA compliance. Management will conclude this enhancement process in the very near future and will take appropriate steps to ensure that the University's information security program is appropriately designed and implemented according to best practices, industry standards, and compliance with all applicable regulations.

Student Financial Assistance Cluster Federal Pell Grant Program 84.063 Federal Supplemental Education Opportunity Grant 84.007 Federal Direct Student Loans 84.268 Federal Work Study Program 84.033 Federal Perkins Loan 84.038 Teacher Education Assistance for College and Higher Education Grants 84.379 Department of Education Program Year 2018-2019 Criteria or specific requirement ? Special Tests ? Disbursements to or on Behalf of Students Condition ? The University is required to notify the parent or student in writing of the date and amount of disbursement, student's or parent's right to cancel all or a portion of that loan or disbursement and have proceeds returned to the holder of the loan or the TEACH Grants payments returned to ED, and the procedure and time by which student or parent must notify institution that they wish to cancel the loan (34 CFR 668.165). Questioned costs ? None Context ? Out of a population of 5,783 students receiving student financial aid, a sample of 25 students was selected for testing. For three of the 25 students tested, the University could not provide support that the student or their parent was notified in writing. Our sampling method was not, and was not intended to be, statistically valid. Effect ? Written notification was not provided. Cause ? The University Counselor who sent the email notifications is no longer employed by the University and the University could not recover the related emails due to a retention policy. Identification of repeat finding ? N/A Recommendation ? The University should consider implementing additional controls to ensure documentation of compliance is maintained. Views of responsible officials and planned corrective actions ? The University will save these emails in a folder accessed by all of the student financial aid department, outside of the email system.

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