EIN: 750800691
UEI: EC4AWY7A7885
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 3, 2025. 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 June 3, 2026 (84 days ago).
What is a management decision? →Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the amounts to be returned to the U.S. Department of Education were correct and notification of a post-withdrawal disbursement could not be located. Questioned costs - $0 Context – Out of the population of 122 students who withdrew, 23 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The R2T4 calculations for 6 students in the sample were correct, but the amount returned to COD was based on the net loan amount rather than the gross amount. The University returned more funds to the COD than was required. Additionally, one student was eligible for a post-withdrawal disbursement, but documentation that the student had been notified was not able to be obtained. Effect – The amount originally returned was incorrect. Cause – The University’s internal controls did not ensure proper inputting of information to return funds. Identification as a repeat finding, if applicable – 2024-001 and 2023-001 Recommendation – The University should update their controls to ensure the R2T4 inputs for the return of funds are correct. Views of responsible officials and planned corrective actions – The University concurs that errors occurred in posting the loan amount to be returned for six (6) Return of Title IV (R2T4) transactions identified during the audit review resulting in a total return of funds for the six (6) students which was $757.56 more than required. Specifically, the actual calculations were completed accurately, but each student’s loan amount was adjusted for loan origination fees when they should not have been adjusted. All updates to records were made for those that required updating. The University also acknowledges that documentation for one student that was required for a post-withdrawal disbursement notification cannot be located. Although the calculation and determination were completed, the supporting documentation of that notification was not properly retained in the student’s record.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the amounts to be returned to the U.S. Department of Education were correct and notification of a post-withdrawal disbursement could not be located. Questioned costs - $0 Context – Out of the population of 122 students who withdrew, 23 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The R2T4 calculations for 6 students in the sample were correct, but the amount returned to COD was based on the net loan amount rather than the gross amount. The University returned more funds to the COD than was required. Additionally, one student was eligible for a post-withdrawal disbursement, but documentation that the student had been notified was not able to be obtained. Effect – The amount originally returned was incorrect. Cause – The University’s internal controls did not ensure proper inputting of information to return funds. Identification as a repeat finding, if applicable – 2024-001 and 2023-001 Recommendation – The University should update their controls to ensure the R2T4 inputs for the return of funds are correct. Views of responsible officials and planned corrective actions – The University concurs that errors occurred in posting the loan amount to be returned for six (6) Return of Title IV (R2T4) transactions identified during the audit review resulting in a total return of funds for the six (6) students which was $757.56 more than required. Specifically, the actual calculations were completed accurately, but each student’s loan amount was adjusted for loan origination fees when they should not have been adjusted. All updates to records were made for those that required updating. The University also acknowledges that documentation for one student that was required for a post-withdrawal disbursement notification cannot be located. Although the calculation and determination were completed, the supporting documentation of that notification was not properly retained in the student’s record.
Corrective Actions: To strengthen internal controls and ensure full compliance with federal regulations, the University has implemented the following measures: 1. Secondary Review Implementation: The University has contracted with an external consultant to serve as a secondary reviewer. In the interim, an internal staff member is receiving comprehensive R2T4 training and will complete the NASFAA Return of Title IV Funds Certification Program in March 2026. Upon completion of the NASFAA Program coursework, the staff member will complete an examination on or before May 31, 2026. Once certification is achieved and the University has full confidence in the internal review process, the secondary review function will transition from the external consultant to an in-house process. 2. Documentation Retention Enhancement: The University has reinforced procedures, including those document retention protocols, by adding this as an additional checklist item on the R2T4 checklist, to ensure that all post-withdrawal disbursement notifications are properly retained in each student’s financial aid record, either electronically or within the designated document management system. The checklist is meant to be a roadmap for the reviewer to ensure each step is completed in the calculation process and that documentation is retained for post-withdrawal disbursement. 3. Staff Training: All financial aid staff involved in the R2T4 process have received updated training on the correct handling of loan returns and post-withdrawal notifications in accordance with 34 CFR 668.22 and current FSA Handbook guidance. Staff involved with R2T4 administration include the Financial Aid Business Analyst and a Financial Aid Advisor. Both team members have completed either official NASFAA or FSA training. The Financial Aid Advisor will be completing the NASFAA Certificate training on R2T4. Additionally, the Assistant Director will also complete the program at the same time, increasing the depth of knowledge for the team around this topic. Responsible Official: Doug Cleary, Director of Financial Aid Estimated Completion Date: May 31, 2026
2024-001, 2023-001
Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University did not report two student’s enrollment changes. The University did not timely report status changes for 20 students. Effect – The University reported incorrect statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Additionally, an incorrect configuration within the University’s student system to cause errors in how enrollment status changes were reported, which resulted in the National Student Clearinghouse placing a temporary hold on all new submissions until the discrepancy was resolved. Identification as repeat finding, if applicable – 2024-002 and 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The University concurs that errors occurred which resulted in the instances of untimely and/or inaccurate student status reporting to the National Student Loan Data System (“NSLDS”) identified during the audit review. Specifically, one parameter setting within the University’s student information system (“SIS”) had been inadvertently configured to populate a data field with information that did not correspond to the enrollment reporting fields accurately in National Student Clearinghouse (“NSC”) or NSLDS. The Registrar’s Office initiated a contemporaneous review of the internal systems working with the University’s service providers to determine the cause of the inaccurate data populating during the enrollment reporting process in award year 2024-2025. That review found that human error contributed to the inaccurate configuration and inaccurate and/or untimely reporting. This appeared to be due in part to a misinterpretation by staff of certain data field(s) in the University’s SIS and the reporting mechanisms between NSC and NSLDS, causing inaccurate and/or untimely enrollment reporting. As part of its response to this audit review, the University continues the review and investigation of its internal systems, service providers, and staff to ensure the root causes of any enrollment reporting deficiencies have been remedied. The University will include, as part of the supplemental Corrective Action Plan, details of that review, plans for analysis and remedial actions currently underway, as well as those corrective measures the University plans to take going forward.
Show full finding ▾Hide full finding ▴Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University did not report two student’s enrollment changes. The University did not timely report status changes for 20 students. Effect – The University reported incorrect statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Additionally, an incorrect configuration within the University’s student system to cause errors in how enrollment status changes were reported, which resulted in the National Student Clearinghouse placing a temporary hold on all new submissions until the discrepancy was resolved. Identification as repeat finding, if applicable – 2024-002 and 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The University concurs that errors occurred which resulted in the instances of untimely and/or inaccurate student status reporting to the National Student Loan Data System (“NSLDS”) identified during the audit review. Specifically, one parameter setting within the University’s student information system (“SIS”) had been inadvertently configured to populate a data field with information that did not correspond to the enrollment reporting fields accurately in National Student Clearinghouse (“NSC”) or NSLDS. The Registrar’s Office initiated a contemporaneous review of the internal systems working with the University’s service providers to determine the cause of the inaccurate data populating during the enrollment reporting process in award year 2024-2025. That review found that human error contributed to the inaccurate configuration and inaccurate and/or untimely reporting. This appeared to be due in part to a misinterpretation by staff of certain data field(s) in the University’s SIS and the reporting mechanisms between NSC and NSLDS, causing inaccurate and/or untimely enrollment reporting. As part of its response to this audit review, the University continues the review and investigation of its internal systems, service providers, and staff to ensure the root causes of any enrollment reporting deficiencies have been remedied. The University will include, as part of the supplemental Corrective Action Plan, details of that review, plans for analysis and remedial actions currently underway, as well as those corrective measures the University plans to take going forward.
Corrective Actions: The University has implemented the following measures with respect to enrollment reporting (“ER”) to strengthen internal controls and ensure full compliance with federal regulations, University policy, and the requirements of NSLDS: 1. Review of ER Systems and Updates Implemented: The University has contracted with external consultants to assist the University in reviewing and reinforcing its ER systems and processes. This work is ongoing and intended to supplement the prior review of the University’s SIS noted in the Response above, which determined a delay in the chronological processing of reports in NSC due to configuration issues in the SIS contributed to the untimely/inaccurate reporting. As a result, the University updated those parameters within its SIS to ensure accurate configuration in Spring 2025. Through this Finding response and the internal and external reviews initiated by the University, Texas Wesleyan has built upon that prior examination to include an analysis of the specific deficiencies noted by auditors and ensure the same have been cured, as well as to implement any necessary compliance measures to safeguard all future ER. In addition to completing any updates required to student-level data in NSC, the University reviewed each deficiency and corresponding student record to discern the cause of the inaccurate data and made necessary systems and/or procedural changes to cure each. First, the University determined that for two of the students with ER errors, additional processes were necessary to capture students enrolled in compressed terms. In collaboration with external consultants and NSC, the Registrar’s Office is developing new processes to ensure accurate ER for these students. This process development is being overseen by Registrar and Associate Provost with a target date for implementation during the initial Spring 2026 7-week compressed terms beginning on January 12th and March 23rd, respectively, subject to testing being conducted with NSC. Second, with respect to graduation status, the University has reviewed the students noted in this Finding with its external consultants and NSC. To ensure that graduation statuses are timely and accurately reported according to University policy and federal requirements, the University is adopting updated procedures to include reporting “G” or “W” status in accordance with guidance from the NSLDS Enrollment Reporting Guide, Section 4.4.4. These procedural updates are being made by the Registrar, overseen by the Associate Provost, and are expected to be finalized by December 5, 2025 Third, together with IT and external consultants, the Registrar’s Office is continuing its review and testing of parameter settings through a comparison of SIS and NSC data to confirm that parameters are accurately configured for ER. The data for this review has been compiled as of the date of this submission and the Registrar is reviewing the data to prepare a comparative report that will be provided to the Working Group (described in Section 2 below) overseen by the Associate Provost. The Registrar’s comparative report to the Working Group is expected to be delivered on January 20, 2026. Finally, as noted below, to ensure timely and accurate reporting and the reconciliation of error reports, the University has implemented several preventive and detective measures with ongoing monitoring and review measures to ensure its compliance. 2. Preventative Measures and Monitoring: The University has integrated, and continues to integrate, updated detective and preventative controls on ER to safeguard the University’s compliance for future reporting by expanding existing reporting controls through regular monitoring efforts to test and review compliance at each reporting level. These preventative measures, monitoring and reconciliation requirements are being overseen by the Associate Provost and include the establishment of a Working Group with external consultants and service providers, as well as stakeholders from the Provost, Registrar, Information Technology, and Financial Aid offices, that meets frequently to review ER, complete the work described in these Corrective Actions, and to ensure discrepancies are discovered and resolved timely and accurately. The Registrar and the Director of Financial Aid also meet monthly to conduct reconciliations of ER which is then reported to the Provost and Associate Provost. In addition to updating its graduation ER procedures, the University has updated its reporting schedule in NSC to provide additional reporting opportunities during the end of the term to ensure all graduation information is timely reported. Finally, the University has met with NSC to review this Finding and its ER practices generally. As a result of that meeting, the University has received from NSC its “Enrollment Reporting Compliance Best Practices Checklist” which the Registrar has provided to all staff in the Registrar’s Office as a guidance document and reference tool for ER. In addition, the Registrar is conducting an office-wide review of the NSC “Enrollment Reporting Compliance Best Practices Checklist” on December 4th, 2025. 3. Staff and Training: In conjunction with this Finding and the internal and external reviews, the University has and continues to review staffing within the Registrar’s Office to ensure appropriate changes have been made as deemed necessary by management. To ensure compliance and accuracy, beginning December 9, 2025, all personnel in the Registrar’s Office will participate in a weekly “Power-Hour” meeting wherein they will complete ER training through NSC, Federal Student Aid, and other resources. This training will continue in accordance with the 2026 training plan and schedule being developed by the Registrar. The training plan and schedule will be delivered to the Associate Provost by January 1, 2026, and is subject to their review and approval. All training and participation will be documented in a report to the Associate Provost. The University has also engaged external consultants to assist staff in ER to ensure compliance and provide secondary review for the Registrar’s Office as needed. Responsible Official: Dr. Helena Bussell, Associate Provost Estimated Completion Date: April 24, 2026
2024-002, 2023-002
FAC accepted this audit on November 26, 2024 — management decision was due May 26, 2025.
Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.
Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 3. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 4. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 5. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.
2023-001, 2022-001
Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Begin Date for 4 students. The University did not report one status change for 3 students who had multiple status changes. The University did not timely report status changes for 3 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.
Show full finding ▾Hide full finding ▴Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Begin Date for 4 students. The University did not report one status change for 3 students who had multiple status changes. The University did not timely report status changes for 3 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.
Finding: 2024-002 Enrollment Reporting Responsible Party: Dr. Karen Jarrell, Director of Office of Student Records and Registrar Completion Date: December 30, 2024 The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post-screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.
2023-002
Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.
Finding: 2024-003 Verification Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: October 17, 2024 The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.
Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.
Finding: 2024-004 Satisfactory Academic Progress Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: July 31, 2024 The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA. The team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.
FAC accepted this audit on December 14, 2023 — management decision was due June 14, 2024.
Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2022-2023 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $1,610 – ALN 84.063; $1,967 – ALN 84.268 Context – Out of the population of 73 students who withdrew, 13 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for 1 of the withdrawals tested was calculated incorrectly and the amount was not returned to the U.S. Department of Education timely. The incorrect withdrawal date was used for 3 students and the incorrect amount was returned for 2 students. Effect – The amount of Title IV funds returned to the U.S. Department of Education was incorrect and the funds were not returned timely. Cause – The University’s internal controls did not ensure proper identification of withdrawal dates for unofficial withdrawals, did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure the amount calculated was returned to the U.S. Department of Education. Identification as a repeat finding, if applicable – 2022-001 and 2021-001 Recommendation – The University should update their controls to ensure that the total days in the semester are calculated correctly based on proper identification of withdrawal dates for unofficial withdrawals, total days attended by students are calculated correctly, unofficial withdrawals are communicated timely, and proper amounts are returned to the U.S. Department of Education. Views of responsible officials and planned corrective actions – All official and unofficial withdrawals are performed by the Office of Student Records. The new university registrar and deputy director are working collaboratively with the Financial Aid Office to follow defined processes and procedures for both official and unofficial withdrawals. The registrar has developed a new standard operating procedure for processing official and unofficial withdrawals. The registrar has already completed the staff training on the new procedure. The Financial Aid Office is responsible for calculating the return of Title IV funds (R2T4). The financial aid administrator selected the wrong template when performing one of the R2T4 calculations in COD. A new internal control procedure has been implemented to ensure that R2T4 calculations are reviewed for accuracy by a second financial aid administrator before being processed.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2022-2023 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $1,610 – ALN 84.063; $1,967 – ALN 84.268 Context – Out of the population of 73 students who withdrew, 13 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for 1 of the withdrawals tested was calculated incorrectly and the amount was not returned to the U.S. Department of Education timely. The incorrect withdrawal date was used for 3 students and the incorrect amount was returned for 2 students. Effect – The amount of Title IV funds returned to the U.S. Department of Education was incorrect and the funds were not returned timely. Cause – The University’s internal controls did not ensure proper identification of withdrawal dates for unofficial withdrawals, did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure the amount calculated was returned to the U.S. Department of Education. Identification as a repeat finding, if applicable – 2022-001 and 2021-001 Recommendation – The University should update their controls to ensure that the total days in the semester are calculated correctly based on proper identification of withdrawal dates for unofficial withdrawals, total days attended by students are calculated correctly, unofficial withdrawals are communicated timely, and proper amounts are returned to the U.S. Department of Education. Views of responsible officials and planned corrective actions – All official and unofficial withdrawals are performed by the Office of Student Records. The new university registrar and deputy director are working collaboratively with the Financial Aid Office to follow defined processes and procedures for both official and unofficial withdrawals. The registrar has developed a new standard operating procedure for processing official and unofficial withdrawals. The registrar has already completed the staff training on the new procedure. The Financial Aid Office is responsible for calculating the return of Title IV funds (R2T4). The financial aid administrator selected the wrong template when performing one of the R2T4 calculations in COD. A new internal control procedure has been implemented to ensure that R2T4 calculations are reviewed for accuracy by a second financial aid administrator before being processed.
Finding Number: 2023-001 Corrective Action: All official and unofficial withdrawals are performed by the Office of Student Records. The new university registrar and deputy director are working collaboratively with the Financial Aid Office to follow defined processes and procedures for both official and unofficial withdrawals. The registrar has developed a new standard operating procedure for processing official and unofficial withdrawals. The registrar has already completed the staff training on the new procedure. The Financial Aid Office is responsible for calculating the return of Title IV funds (R2T4). The financial aid administrator selected the wrong template when performing one of the R2T4 calculations in COD. A new internal control procedure has been implemented to ensure that R2T4 calculations are reviewed for accuracy by a second financial aid administrator before being processed. Responsible: Karen Jarrell, University Registrar, and Elaine Robinson, Director of Financial AidCompletion Date: November 1, 2023
2022-001, 2021-001
Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2022-2023 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 657 students with student attendance changes required to be reported prior to July 19, 2022 or after February 28, 2023, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Length for 1 student. The University reported the incorrect Program Begin Date for 4 students. The University reported the incorrect Program Enrollment Status for 1 student. The University reported the incorrect Campus Enrollment and Program Enrollment Effective Date for 1 student. The University did not timely report status changes for 17 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – Enrollment reporting is performed by the Office of Student Records. The new university registrar has modified the enrollment reporting process to include audits of all student-related data prior to census day. Any changes in student academic program received after census day will be effective for the next academic semester. Additionally, the registrar created procedural changes to ensure reporting happens for every reporting period with the added redundancy of additional staff. All reporting periods are recorded on the Office of Student Records' office calendar and in their processing action plan document.
Show full finding ▾Hide full finding ▴Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2022-2023 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 657 students with student attendance changes required to be reported prior to July 19, 2022 or after February 28, 2023, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Length for 1 student. The University reported the incorrect Program Begin Date for 4 students. The University reported the incorrect Program Enrollment Status for 1 student. The University reported the incorrect Campus Enrollment and Program Enrollment Effective Date for 1 student. The University did not timely report status changes for 17 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – Enrollment reporting is performed by the Office of Student Records. The new university registrar has modified the enrollment reporting process to include audits of all student-related data prior to census day. Any changes in student academic program received after census day will be effective for the next academic semester. Additionally, the registrar created procedural changes to ensure reporting happens for every reporting period with the added redundancy of additional staff. All reporting periods are recorded on the Office of Student Records' office calendar and in their processing action plan document.
Finding Number: 2023-002 Corrective Action: Enrollment reporting is performed by the Office of Student Records. The new university registrar has modified the enrollment reporting process to include audits of all student-related data prior to census day. Any changes in student academic program received after census day will be effective for the next academic semester. Additionally, the registrar created procedural changes to ensure reporting happens for every reporting period with the added redundancy of additional staff. All reporting periods are recorded on the Office of Student Records’ office calendar and in their processing action plan document. Responsible: Karen Jarrell, University Registrar Completion Date: November 1, 2023
FAC accepted this audit on November 29, 2022 — management decision was due May 29, 2023.
Criteria or specific requirement ? Special Tests and Provisions ? Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition ? The University?s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context ? Out of the population of 37 students who withdrew, 6 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One of the withdrawals tested had more returned to the U.S. Department of Education than was required and the amounts were returned approximately 6 months after the withdrawal. Effect ? The amount of Title IV funds returned to the U.S. Department of Education was incorrect and the funds were not returned timely. Cause ? The student who withdrew was attending two modules in one payment period and withdrew from both modules. The calculation of days attended was incorrect. Identification as a repeat finding, if applicable ? 2021-001 and 2020-001 Recommendation ? The University should update their controls to ensure that the days attended for students who withdrawal from a program offered in modules is correct. Views of responsible officials and planned corrective actions ? The Financial Aid Administrator acknowledges the error with the Title IV Calculation for the student who was enrolled in two modules in one semester. Initially, the calculation was based on the student being enrolled in one module. When the file was chosen for the 2021-2022 audit, the error was caught that the student was enrolled in module two, as well. The Director of Financial Aid has reached out to ?Ask a Fed? for guidance on the calculation of the numerator in a Title IV calculation about modules. Once guidance is received, we will incorporate it into our procedures and provide training to staff.
Show full finding ▾Hide full finding ▴Criteria or specific requirement ? Special Tests and Provisions ? Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition ? The University?s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context ? Out of the population of 37 students who withdrew, 6 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One of the withdrawals tested had more returned to the U.S. Department of Education than was required and the amounts were returned approximately 6 months after the withdrawal. Effect ? The amount of Title IV funds returned to the U.S. Department of Education was incorrect and the funds were not returned timely. Cause ? The student who withdrew was attending two modules in one payment period and withdrew from both modules. The calculation of days attended was incorrect. Identification as a repeat finding, if applicable ? 2021-001 and 2020-001 Recommendation ? The University should update their controls to ensure that the days attended for students who withdrawal from a program offered in modules is correct. Views of responsible officials and planned corrective actions ? The Financial Aid Administrator acknowledges the error with the Title IV Calculation for the student who was enrolled in two modules in one semester. Initially, the calculation was based on the student being enrolled in one module. When the file was chosen for the 2021-2022 audit, the error was caught that the student was enrolled in module two, as well. The Director of Financial Aid has reached out to ?Ask a Fed? for guidance on the calculation of the numerator in a Title IV calculation about modules. Once guidance is received, we will incorporate it into our procedures and provide training to staff.
Texas Wesleyan University Corrective Action Plan 2021 Academic Year (Summer 21, Fall 21, Spring 22) Fiscal Year Ending May 31, 2022 Reference Number: 2022-001 Recommendation: The University should update its controls to ensure that the days attended for students who withdraw from a program offered in modules is correct. Corrective Action Plan: The Financial Aid Administrator acknowledges the error with the Title IV Calculation for the student who was enrolled in two modules in one semester. Initially, the calculation was based on the student being enrolled in one module. When the file was chosen for the 2021-2022 audit, the error was caught that the student was enrolled in module two, as well. The Director of Financial Aid has reached out to ?Ask a Fed? for guidance on the calculation of the numerator in a Title IV calculation about modules. The guidance was received on September 1, 2022, and confirmed that the numerator should only include the actual days the student attended. This guidance has been implemented. The 2021-2022 return of funds for students enrolled in the modules will be recalculated by October 31, 2022.
2021-001
FAC accepted this audit on November 28, 2021 — management decision was due May 28, 2022.
Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, CFDA 84.007; Federal Work-Study Program, CFDA 84.033 Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loans, CFDA 84.268 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 U. S. Department of Education Program Year 2020-2021 Criteria or specific requirement ? Special Tests and Provisions - Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5)). Condition ? The University?s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct. Questioned costs ? $0 Context ? Out of the population of 80 refund calculations that were performed during the year, a sample of 12 refunds were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Seven of the withdrawals tested had more returned to the U.S. Department of Education than was required. The days in the fall semester were not properly set up in the University?s system to calculate the percentage of federal aid earned. Effect ? The amount of Title IV funds returned to the U.S. Department of Education was incorrect. Cause ? The days in the fall semester were set up for all students to end at the end of a mini-session that was attached to the semester. None of the students tested were enrolled in the mini-session, so they days in the semester and percentage completed when the student withdrew were incorrect. The University?s internal controls did not ensure these were properly set up in the system. Identification as repeat finding, if applicable ? 2020-001 Recommendation ? The University should update their controls to ensure that the days in the semester are properly calculated. Views of responsible officials and planned corrective actions ? Texas Wesleyan University financial aid administrators acknowledge that the interpretation of the academic calendar for Fall 21 has been challenging. During the federal program review, it was pointed out to the financial aid administration that the dates reported to the Common Origination Department (COD) did not match full reporting Fall 21 term. The academic calendar includes a third mini-session that extends beyond the end of the Fall term. The Director of Financial Aid sought guidance from the Department of Education as to how to handling the third mini-session for the Fall 20 term. The University is correcting their academic calendar for the 2022-2023 academic year. The Financial Aid Office has been working with the Registrar and Faculty to create an academic calendar that Colleague will be able to calculate R2T4?s correctly.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, CFDA 84.007; Federal Work-Study Program, CFDA 84.033 Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loans, CFDA 84.268 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 U. S. Department of Education Program Year 2020-2021 Criteria or specific requirement ? Special Tests and Provisions - Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5)). Condition ? The University?s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct. Questioned costs ? $0 Context ? Out of the population of 80 refund calculations that were performed during the year, a sample of 12 refunds were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Seven of the withdrawals tested had more returned to the U.S. Department of Education than was required. The days in the fall semester were not properly set up in the University?s system to calculate the percentage of federal aid earned. Effect ? The amount of Title IV funds returned to the U.S. Department of Education was incorrect. Cause ? The days in the fall semester were set up for all students to end at the end of a mini-session that was attached to the semester. None of the students tested were enrolled in the mini-session, so they days in the semester and percentage completed when the student withdrew were incorrect. The University?s internal controls did not ensure these were properly set up in the system. Identification as repeat finding, if applicable ? 2020-001 Recommendation ? The University should update their controls to ensure that the days in the semester are properly calculated. Views of responsible officials and planned corrective actions ? Texas Wesleyan University financial aid administrators acknowledge that the interpretation of the academic calendar for Fall 21 has been challenging. During the federal program review, it was pointed out to the financial aid administration that the dates reported to the Common Origination Department (COD) did not match full reporting Fall 21 term. The academic calendar includes a third mini-session that extends beyond the end of the Fall term. The Director of Financial Aid sought guidance from the Department of Education as to how to handling the third mini-session for the Fall 20 term. The University is correcting their academic calendar for the 2022-2023 academic year. The Financial Aid Office has been working with the Registrar and Faculty to create an academic calendar that Colleague will be able to calculate R2T4?s correctly.
Reference Number: 2021-001 Corrective Action Plan - Texas Wesleyan University financial aid administrators acknowledge that the interpretation of the academic calendar for Fall 21 has been challenging. During the federal program review, it was pointed out to the financial aid administration that the dates reported to the Common Origination Department (COD) did not match the full reporting Fall 21 term. The academic calendar includes a third mini-session that extends beyond the end of the Fall term. The Director of Financial Aid sought guidance from the Department of Education, as to how to handle the third mini-session for the Fall 20 term. The University is correcting their academic calendar for the 2022-2023 academic year. The Financial Aid Office has been working with the Registrar and Faculty to create an academic calendar that Colleague will be able to calculate R2T4?s correctly. Responsible Official ? Elaine Robinson, Director of Financial Aid and Veterans Estimated Completion ? Effective immediately, the dates reported to COD will be used to calculate R2T4s. Updates to the academic catalog will be made for the Fall 2022 semester.
2020-001
Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Teacher Education Assistance for College and Higher Education Grants (TEACH), CFDA 84.379 U.S. Department of Education Program Year 2020-2021 Criteria or specific requirement ? Special Tests and Provisions ? Disbursements to or on Behalf of Students (34 CFR 668.165). Condition ? The University?s internal controls did not ensure that notifications were sent to the student or parent the date and amount of loans or TEACH grants disbursed, the student?s or parent?s right to cancel all or a portion of that loan or loan disbursement and have the procedures returned, and the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH grant disbursement. Questioned costs ? $0 Context ? The University did not have a procedure in place to ensure the required communications were made when loans or TEACH grants were disbursed during the 2020-2021 academic year. Effect ? The University did not meet the requirements to notify the students or parents in a timely manner of their loan or TEACH grant disbursements and rights to cancel all or a portion of the loans or grants. Cause ? The automatic notification was disabled in the University?s system during the 2020-2021 academic year. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure that notifications are made within the required timeframe to notify students or parents their right to cancel the loans or grants. Views of responsible officials and planned corrective actions ? Texas Wesleyan University Financial Aid Administrators acknowledge that the notifications for the loans or TEACH grant disbursements and rights to cancel all or a portion of the loans or grants was disabled in the 2018-2019 academic year. During the federal program review of the 2018-19 academic year that was performed in June 2021, it was brought to the Director of Financial Aid?s attention. Corrective action was taken, immediately, to rectify this oversight. The required notifications were sent for Fall 2021.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Teacher Education Assistance for College and Higher Education Grants (TEACH), CFDA 84.379 U.S. Department of Education Program Year 2020-2021 Criteria or specific requirement ? Special Tests and Provisions ? Disbursements to or on Behalf of Students (34 CFR 668.165). Condition ? The University?s internal controls did not ensure that notifications were sent to the student or parent the date and amount of loans or TEACH grants disbursed, the student?s or parent?s right to cancel all or a portion of that loan or loan disbursement and have the procedures returned, and the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH grant disbursement. Questioned costs ? $0 Context ? The University did not have a procedure in place to ensure the required communications were made when loans or TEACH grants were disbursed during the 2020-2021 academic year. Effect ? The University did not meet the requirements to notify the students or parents in a timely manner of their loan or TEACH grant disbursements and rights to cancel all or a portion of the loans or grants. Cause ? The automatic notification was disabled in the University?s system during the 2020-2021 academic year. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure that notifications are made within the required timeframe to notify students or parents their right to cancel the loans or grants. Views of responsible officials and planned corrective actions ? Texas Wesleyan University Financial Aid Administrators acknowledge that the notifications for the loans or TEACH grant disbursements and rights to cancel all or a portion of the loans or grants was disabled in the 2018-2019 academic year. During the federal program review of the 2018-19 academic year that was performed in June 2021, it was brought to the Director of Financial Aid?s attention. Corrective action was taken, immediately, to rectify this oversight. The required notifications were sent for Fall 2021.
Reference Number: 2021-002 Corrective Action Plan - Texas Wesleyan University Financial Aid Administrators acknowledge that the notifications for the loans or TEACH grant disbursements and rights to cancel all or a portion of the loans or grants was disabled in the 2018-2019 academic year. During the federal program review of the 2018-19 academic year that was performed in June 2021, it was brought to the Director of Financial Aid?s attention. Responsible Official ? Elaine Robinson, Director of Financial Aid and Veterans Estimated Completion ? Corrective action was taken, immediately, to rectify this oversight. The required notifications were sent for Fall 2021.
Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, CFDA 84.007; Federal Work-Study Program, CFDA 84.033 Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loans, CFDA 84.268 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 U.S. Department of Education Program Year 2020-2021 Criteria or specific requirement ? Special Tests and Provisions ? Verification (34 CFR 668.53). Condition ? The University?s internal controls did not ensure data corrections were submitted to the central processor after students? information was verified. Questioned costs ? $0 Context ? Out of a population of 397 students receiving federal aid who were selected by ED for verification, a sample of 40 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. For five of the students selected, the data corrections related to the number of people in the household or number of students in college was not submitted to the central processor. Additionally, the verification files for one student tested was unable to be located. Effect ? The information verified did not match the data submitted to the central processor. Cause ? The University?s controls did not ensure updates from verification were submitted to the central processor. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure changes student data from verifications is submitted to the central processor and any changes in awards are made due to changes in the student?s expected family contribution. Views of responsible officials and planned corrective actions ? Texas Wesleyan University financial aid administrators acknowledge the errors found during verification for the 2020-2021 academic year. The Financial Aid office has experienced a lot of turnovers, and training has not been consistent. Texas Wesleyan University administration has invested in future training for the Financial Aid Office. Processes are being streamlined to ensure that all financial aid advisors are consistently awarding each file, going forward. In conjunction, the staff is being trained monthly on various regulatory issues within the financial aid community.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, CFDA 84.007; Federal Work-Study Program, CFDA 84.033 Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loans, CFDA 84.268 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 U.S. Department of Education Program Year 2020-2021 Criteria or specific requirement ? Special Tests and Provisions ? Verification (34 CFR 668.53). Condition ? The University?s internal controls did not ensure data corrections were submitted to the central processor after students? information was verified. Questioned costs ? $0 Context ? Out of a population of 397 students receiving federal aid who were selected by ED for verification, a sample of 40 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. For five of the students selected, the data corrections related to the number of people in the household or number of students in college was not submitted to the central processor. Additionally, the verification files for one student tested was unable to be located. Effect ? The information verified did not match the data submitted to the central processor. Cause ? The University?s controls did not ensure updates from verification were submitted to the central processor. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure changes student data from verifications is submitted to the central processor and any changes in awards are made due to changes in the student?s expected family contribution. Views of responsible officials and planned corrective actions ? Texas Wesleyan University financial aid administrators acknowledge the errors found during verification for the 2020-2021 academic year. The Financial Aid office has experienced a lot of turnovers, and training has not been consistent. Texas Wesleyan University administration has invested in future training for the Financial Aid Office. Processes are being streamlined to ensure that all financial aid advisors are consistently awarding each file, going forward. In conjunction, the staff is being trained monthly on various regulatory issues within the financial aid community.
Reference Number: 2021-003 Corrective Action Plan - Texas Wesleyan University financial aid administrators acknowledge the errors found during verification for the 2020-2021 academic year. The Financial Aid office has experienced a lot of turnovers, and training has not been consistent. Texas Wesleyan University administration has invested in future training for the Financial Aid Office. Processes are being streamlined to ensure that all financial aid advisors are consistently awarding each file, going forward. In conjunction, the staff is being trained monthly on various regulatory issues within the financial aid community. Responsible Official ? Elaine Robinson, Director of Financial Aid and Veterans Estimated Completion ? November 2021
FAC accepted this audit on June 29, 2021 — management decision was due December 29, 2021.
Criteria or specific requirement ? Special Tests and Provisions - Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5)). Condition ? The University?s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct. Questioned costs ? $0 Context ? Out of the population of 68 refund calculations that were performed during the year, a sample of 7 refunds were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Two of the withdrawals tested had more returned to the U.S. Department of Education than was required. The seven week summer courses were not properly set up in the University?s system to calculate the aid; and the number of days of breaks greater than five days was incorrect for the fall semester. Effect ? The amount of Title IV funds returned to the U.S. Department of Education was incorrect. Cause ? The seven-week summer courses were not properly set up in the University?s system to calculate the aid and the number of days of breaks greater than five days was incorrect for the fall semester. The University?s internal controls did not ensure these were properly set up in the system. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure that the days in the semester are properly calculated.
Show full finding ▾Hide full finding ▴Criteria or specific requirement ? Special Tests and Provisions - Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5)). Condition ? The University?s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct. Questioned costs ? $0 Context ? Out of the population of 68 refund calculations that were performed during the year, a sample of 7 refunds were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Two of the withdrawals tested had more returned to the U.S. Department of Education than was required. The seven week summer courses were not properly set up in the University?s system to calculate the aid; and the number of days of breaks greater than five days was incorrect for the fall semester. Effect ? The amount of Title IV funds returned to the U.S. Department of Education was incorrect. Cause ? The seven-week summer courses were not properly set up in the University?s system to calculate the aid and the number of days of breaks greater than five days was incorrect for the fall semester. The University?s internal controls did not ensure these were properly set up in the system. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure that the days in the semester are properly calculated.
Response and Action Plan - Texas Wesleyan University financial aid administrators acknowledge this error. A Return to Title IV (R2T4) calculation involves more than the Financial Aid Office. The Financial Aid Office is working closely with the Registrar?s office to ensure that we are kept in the loop of any changes to the Academic Calendar. During each New Year set-up, the Registrar will be contacted to confirm the Academic Calendar and all scheduled breaks to ensure that the form that calculates the R2T4?s is set up correctly. In conjunction, the financial aid administrators will work closely with the Registrar?s office to ensure that if the Academic Calendar has any changes during the year, the financial aid office will be notified immediately. Responsible Person: Elaine Robinson, Director of Financial Aid Estimated Completion- Completed May 2021
Criteria or specific requirement ? Special Tests and Provisions ? Distance Education Program (34 CFR 668.8(m)). Condition ? The University?s internal controls did not ensure attendance for students awarded Title IV funds that were enrolled in distance education programs to be properly recorded and to determine identified students began attendance or to determine a last date of attendance for Return of Title IV purposes. Questioned costs ? $0 Context ? Out of the population of 358 distance education program courses, a sample of 40 student courses were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. For eleven of the students tested, the attendance rosters were not submitted to the registrar to document attendance. Effect ? The University?s controls did not properly record attendance for students awarded Title IV funds that were enrolled in distance education programs. Cause ? The University?s internal controls for distance education attendance monitoring were not consistently followed. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure student attendance is monitored to determine if students began attendance or to determine a last date of attendance for return of Title IV purposes.
Show full finding ▾Hide full finding ▴Criteria or specific requirement ? Special Tests and Provisions ? Distance Education Program (34 CFR 668.8(m)). Condition ? The University?s internal controls did not ensure attendance for students awarded Title IV funds that were enrolled in distance education programs to be properly recorded and to determine identified students began attendance or to determine a last date of attendance for Return of Title IV purposes. Questioned costs ? $0 Context ? Out of the population of 358 distance education program courses, a sample of 40 student courses were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. For eleven of the students tested, the attendance rosters were not submitted to the registrar to document attendance. Effect ? The University?s controls did not properly record attendance for students awarded Title IV funds that were enrolled in distance education programs. Cause ? The University?s internal controls for distance education attendance monitoring were not consistently followed. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure student attendance is monitored to determine if students began attendance or to determine a last date of attendance for return of Title IV purposes.
Response and Action Plan ? the University?s Office of Student Records will continue to send class 6th day and 12th day rosters (3-day roster for 7-week, SUI, SUII classes) for review and verification using EAB Navigate. The Deans, or their designee of the schools will contact faculty with outstanding 3-day census class rosters to ensure that the rosters are returned to the Office of Student Records within three days of its respective due date. The Deans, or their designee of the schools will contact faculty with outstanding 6th or 12th day census day class rosters to ensure that the rosters are returned to the Office of Student Records within three weeks of their respective due dates. Responsible Person: Sloan K. White, University Registrar Estimated Completion ? Completed May 2021
Criteria or specific requirement ? Special Tests and Provisions ? Enrollment Reporting (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition ? The University?s internal controls did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs ? $0 Context ? Out of the population of 1,298 students with student attendance changes a sample of 40 student changes were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were three attributes tested for each student with a status change: 1. University?s records match NSLDS for the date of the change; 2. University?s records match NSLDS for the type of change; and 3. Changes were reported timely. The effective date did not match on four of the students tested and the changes were not reported timely for two students tested Effect ? The University reported incorrect dates for students? status changes and did not report the status changes timely. Cause ? The University?s controls did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure changes in students enrollment status are reported in a timely and accurate manner.
Show full finding ▾Hide full finding ▴Criteria or specific requirement ? Special Tests and Provisions ? Enrollment Reporting (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition ? The University?s internal controls did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs ? $0 Context ? Out of the population of 1,298 students with student attendance changes a sample of 40 student changes were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were three attributes tested for each student with a status change: 1. University?s records match NSLDS for the date of the change; 2. University?s records match NSLDS for the type of change; and 3. Changes were reported timely. The effective date did not match on four of the students tested and the changes were not reported timely for two students tested Effect ? The University reported incorrect dates for students? status changes and did not report the status changes timely. Cause ? The University?s controls did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable ? N/A Recommendation ? The University should update their controls to ensure changes in students enrollment status are reported in a timely and accurate manner.
Response and Action Plan ? The Registrar will send a final `Subsequent of Term? enrollment file to the National Student Clearinghouse after the term ends. This will ensure status changes are picked up and transmitted to NSLDS in a timely manner after the term ends and within the reporting window for NSLDS. Additionally, the Registrar will gain access and training to NSLDS to manually update statuses as needed to ensure compliance with effective dates. Responsible Person: Sloan K. White, University Registrar Estimated Completion ? August 2021
FAC accepted this audit on November 13, 2018 — management decision was due May 13, 2019.
GSA_MIGRATION
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