EIN: 750808791
UEI: LDDBB2MZFUH5
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 22, 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 March 22, 2026 (160 days ago).
What is a management decision? →FAC accepted this audit on September 16, 2024 — management decision was due March 16, 2025.
FAC accepted this audit on October 4, 2023 — management decision was due April 4, 2024.
FAC accepted this audit on October 12, 2022 — management decision was due April 12, 2023.
FAC accepted this audit on September 2, 2021 — management decision was due March 2, 2022.
There were two incorrect calculations of returned funds for students that withdrew during the term. Criteria: 34 CFR 668.22 Questioned Costs: $1,205 Context: 2 of 14 withdrawals tested had a R2T4 calculation error. Cause: One student had not accepted the direct loan aid, so it showed as pending. Since the student never accepted the loans, they should not have been included as aid that could have been disbursed which resulted in Pell being required to be returned. This was returned during the audit process. Another undergraduate student had registered for an 8-week module in the second half the semester, and the withdrawal date was prior to beginning that module. The University appropriately reduced Pell to the amount of credits the student had begun attendance in, but the R2T4 calculation inadvertently included the original disbursement of Pell instead of the reduction of Pell, which resulted in $518 of subsidized loans being returned that was not required to be returned. Effect: The Pell was not returned until the audit, and subsidized loans were returned when they were not required to be returned. Recommendation: We recommend the University add a check for whether the loans have been accepted or not. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-001 Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Student Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2020-2021 Financial Aid Year Condition: There were two incorrect calculations of returned funds for students that withdrew during the term. Criteria: 34 CFR 668.22 Questioned Costs: $1,205 Context: 2 of 14 withdrawals tested had a R2T4 calculation error. Cause: One student had not accepted the direct loan aid, so it showed as pending. Since the student never accepted the loans, they should not have been included as aid that could have been disbursed which resulted in Pell being required to be returned. This was returned during the audit process. Another undergraduate student had registered for an 8-week module in the second half the semester, and the withdrawal date was prior to beginning that module. The University appropriately reduced Pell to the amount of credits the student had begun attendance in, but the R2T4 calculation inadvertently included the original disbursement of Pell instead of the reduction of Pell, which resulted in $518 of subsidized loans being returned that was not required to be returned. Effect: The Pell was not returned until the audit, and subsidized loans were returned when they were not required to be returned. Recommendation: We recommend the University add a check for whether the loans have been accepted or not. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-001 R2T4 Calculations Planned Corrective Action: In order to meet the R2T4 requirements of evaluating aid that could have been disbursed, we have updated our withdrawal procedure to review award action status codes of federal direct loans more closely. We award a direct loan as an action status of Q; we move the action status to an O once MPN/ELC are completed and received from DoE. The student then accepts the loan moving that action status to an S. Once the student accepts the loan and it is posted to their student account, the loan record is sent to COD and the loan is originated. According to regulation, aid that could have been disbursed would only include originated federal direct loans. If the student never accepts the loan, then it would not be aid that could have been disbursed. We have updated our withdrawal procedures to include a more comprehensive review of undergraduate, Pell eligible students enrolled in payment periods with modules. Updated procedures will include Pell recalculation prior to R2T4 calculation if the student had not yet begun attendance in all courses. Specifically, this will include checking the registration statement for course start dates within a payment period. Person Responsible for Corrective Action Plan: Monica Smart, Director of Financial Aid Anticipated Date of Completion: August 20, 2021 Finding Number: 2021-002 Federal Direct Loan Annual Limits
A student was overawarded subsidized loans. Criteria: 34 CFR 685.203 Questioned Costs: $1,000 Context: 1 of 53 students tested for proper awarding of direct loans received the junior level of subsidized loans when the credits earned were at the sophomore level. Cause: The system rules were tied to incorrect credit hours. The University was aware of the system set up being incorrect and was manually adjusting students. This student was a manual oversight in adjustment. Effect: The student received $1,000 in subsidized loans that they were not eligible to receive. Recommendation: We recommend the University adjust system rules. The University corrected the system rules for the 2021-2022 fiscal year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-002 Federal Direct Loan Annual Limits DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2020-2021 Financial Aid Year Condition: A student was overawarded subsidized loans. Criteria: 34 CFR 685.203 Questioned Costs: $1,000 Context: 1 of 53 students tested for proper awarding of direct loans received the junior level of subsidized loans when the credits earned were at the sophomore level. Cause: The system rules were tied to incorrect credit hours. The University was aware of the system set up being incorrect and was manually adjusting students. This student was a manual oversight in adjustment. Effect: The student received $1,000 in subsidized loans that they were not eligible to receive. Recommendation: We recommend the University adjust system rules. The University corrected the system rules for the 2021-2022 fiscal year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-002 Federal Direct Loan Annual Limits Planned Corrective Action: In order to properly assign federal direct loan amounts, we have updated colleague system rules to align with the academic catalog regarding grade level progression. Additionally, we have corrected our direct loan chart, policy and procedure guide, and My Financial Aid guide. Person Responsible for Corrective Action Plan: Monica Smart, Director of Financial Aid Anticipated Date of Completion: August 1, 2021
FAC accepted this audit on September 10, 2020 — management decision was due March 10, 2021.
Pell was not awarded to students based on eligibility. Criteria: 34 CFR 690 Subpart F and G Questioned Costs: $2,299 Context: Out of 28 students tested, 4 students were not awarded Pell for enrollment in the summer 2019 term. As part of the audit process, the University reviewed all Pell eligible students enrolled in the summer 2019 term and disbursed an additional $28,463 for this term which included these 4 students. This was completed by June 30, 2020. In addition, 1 student was under awarded Pell by $2,200 when their expected family contribution (EFC) decreased based on changes from verification. This student was corrected as part of the audit process. One other student was disbursed Pell for full time enrollment but the student ended up taking only 1 class and therefore, was over awarded Pell by 2,299. The student was corrected as part of the audit process and funds were returned to the Department of Education. Effect: Students not awarded Pell grants based on eligibility. Cause: The University only awarded Pell grants for summer if a student requested aid for that term. The University didn?t review Pell eligibility based on enrollment status changes or changes in EFC when verification was completed. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University put procedures in place to review Pell eligibility in all terms especially when there are enrollment and EFC changes. Views of Responsible Officials and Corrective Action Plan: Management agrees with the findings and is in the process of addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-002 Inaccurate Pell Awards Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.063 Federal Award Identification #: 19/20 Financial Aid Year Condition: Pell was not awarded to students based on eligibility. Criteria: 34 CFR 690 Subpart F and G Questioned Costs: $2,299 Context: Out of 28 students tested, 4 students were not awarded Pell for enrollment in the summer 2019 term. As part of the audit process, the University reviewed all Pell eligible students enrolled in the summer 2019 term and disbursed an additional $28,463 for this term which included these 4 students. This was completed by June 30, 2020. In addition, 1 student was under awarded Pell by $2,200 when their expected family contribution (EFC) decreased based on changes from verification. This student was corrected as part of the audit process. One other student was disbursed Pell for full time enrollment but the student ended up taking only 1 class and therefore, was over awarded Pell by 2,299. The student was corrected as part of the audit process and funds were returned to the Department of Education. Effect: Students not awarded Pell grants based on eligibility. Cause: The University only awarded Pell grants for summer if a student requested aid for that term. The University didn?t review Pell eligibility based on enrollment status changes or changes in EFC when verification was completed. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University put procedures in place to review Pell eligibility in all terms especially when there are enrollment and EFC changes. Views of Responsible Officials and Corrective Action Plan: Management agrees with the findings and is in the process of addressing the issue. See corrective action plan.
Finding Number: 2020-002 Inaccurate Pell Awards Planned Corrective Action: To ensure that all students are properly awarded and paid Pell Grant during the summer term, the Financial Aid Counselor will pull a summer registration report from the system twice a week to check for Pell eligible students (registered hours, EFC, and LEU). the Financial Aid Counselor the Pell calculator to determine the amount of the award and adds the award. To ensure the funds are paid, he accepts the award for the student (unless they?re in verification, in which case it?s added on hold pending completion of verification). The awarding of Pell by the Financial Aid Counselor is completed under the oversight of the Assistant Director and Director of Financial Aid. In addition, all summer Pell awards will be reviewed by the Director and Assistant Director at the Pell recalculation date. Finally, the Financial Aid Counselor will continue assessing Pell eligibility for late FAFSA filers throughout the award year. This will be reviewed by the Director and Assistant Director. Person Responsible for Corrective Action Plan: Monica Smart ? Director of Financial Aid Anticipated Date of Completion: The corrections to Summer 2019 Pell were completed in late June and early July 2020. The above process for awarding summer Pell for summer 2020 began in early April 2020 and is ongoing.
FAC accepted this audit on October 22, 2019 — management decision was due April 22, 2020.
Finding 2019-001 Federal Agency Name: U.S. Department of Education Program Name: Federal Perkins Loan Program and Federal Pell Grant CFDA: 84.268 and 84.063 Federal Award Number: P268K182273 Award Year: 2018/2019 Type of Finding: Material Weakness in Internal Control over Compliance Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria The University is required to have procedures in place to assure student enrollment statuses are submitted to NSLDS in accordance with 34 CFR 685.309, which reads that ?A School shall? 1) Upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 15 days of receipt; and 2) Unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who? a. Enrolled at that school but has ceased to be enrolled on at least a half-time basis; b. Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period for which the loan was intended [?]? If a school elects to establish a transmission schedule with NSLDS for a frequency less often than every two months, the school must report a student enrollment status change within 30 days if the student drops below half-time, withdraws, or graduates. Condition Two of the 60 students tested did not have the correct status change reported to NSLDS. One of the student?s status was also not reported within 60 days. Cause Designed internal controls over enrollment reporting requirements were not followed as required by the University?s processes. Effect Without properly designed internal controls over enrollment reporting, errors or omissions could occur affecting the accuracy of repayment of a student?s loan. Questioned Costs None reported. Context/Sampling A nonstatistical sample of 60 students out of 223 students was selected for student status change testing. Repeat Finding from Prior Year Yes, Finding 2018-001 Recommendation We recommend that procedures be reviewed to ensure that enrollment status changes are submitted within the required timeframe and accurately reflect the student?s academic records. Views of Responsible Individuals Management agrees with the finding.
Show full finding ▾Hide full finding ▴Finding 2019-001 Federal Agency Name: U.S. Department of Education Program Name: Federal Perkins Loan Program and Federal Pell Grant CFDA: 84.268 and 84.063 Federal Award Number: P268K182273 Award Year: 2018/2019 Type of Finding: Material Weakness in Internal Control over Compliance Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria The University is required to have procedures in place to assure student enrollment statuses are submitted to NSLDS in accordance with 34 CFR 685.309, which reads that ?A School shall? 1) Upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 15 days of receipt; and 2) Unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who? a. Enrolled at that school but has ceased to be enrolled on at least a half-time basis; b. Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period for which the loan was intended [?]? If a school elects to establish a transmission schedule with NSLDS for a frequency less often than every two months, the school must report a student enrollment status change within 30 days if the student drops below half-time, withdraws, or graduates. Condition Two of the 60 students tested did not have the correct status change reported to NSLDS. One of the student?s status was also not reported within 60 days. Cause Designed internal controls over enrollment reporting requirements were not followed as required by the University?s processes. Effect Without properly designed internal controls over enrollment reporting, errors or omissions could occur affecting the accuracy of repayment of a student?s loan. Questioned Costs None reported. Context/Sampling A nonstatistical sample of 60 students out of 223 students was selected for student status change testing. Repeat Finding from Prior Year Yes, Finding 2018-001 Recommendation We recommend that procedures be reviewed to ensure that enrollment status changes are submitted within the required timeframe and accurately reflect the student?s academic records. Views of Responsible Individuals Management agrees with the finding.
Finding 2019-001 Federal Agency Name: U.S. Department of Education Program Name: Federal Perkins Loan Program and Federal Pell Grant CFDA #84.268 and 84.063 Finding Summary: In accordance with 34 CFR 685.309, the University has 60 days to complete and return an updated student status confirmation to National Student Loan Data System (NSLDS) through the National Clearing House. Two of the 60 students tested did not have the correct status change reported to NSLDS. One of the student?s status was also not reported within 60 days. Corrective Action Plan (CAP): The Registrar will perform a detailed review of each enrollment submission to NSLDS. The Registrar will also review all error reports received from National Clearinghouse and ensure that errors are resolved by the Records/Publications Coordinator in a timely manner. Financial Aid will continue reviewing a sample of status changes. This review will be expanded to include all statuses (e.g. full time, half-time) versus only status changes due to students graduating or withdrawing. Anticipated Completion Date: The corrective action plan will be implemented immediately.
2018-001
Finding 2019-002 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster (Federal Work Study, Federal Supplemental Educational Opportunity Grant, Federal Pell Grant, Federal Perkins Loan Program, Federal Direct Student Loan Program and Nurse Faculty Loan Program) CFDA: 84.033, 84.007, 84.063, 84,038, 84.268 and 93.264 Federal Award Number: P268K182273 Award Year: 2018/2019 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Compliance Requirement: Special Tests and Provisions ? Return to Title IV Criteria: The University is required to have procedures in place when a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement as in accordance with 34 CFR sections 668.22(a)(1) through (a)(5). Condition 16 of the 16 students tested had the incorrect calculation of Title IV funds to be returned upon withdrawal from the University. Upon further review by management, as a result of the original finding, it was noted that incorrect dates were used for the Spring semester calculations as well as some incorrect amounts for Fall and Spring semesters. Cause Designed internal controls over Return to Title IV calculation requirements were not followed as required by the University?s processes. Effect Without properly designed internal controls over Title IV calculation requirements, errors or omissions could occur affecting the accuracy of returned funds. Questioned Costs $26,597 Context/Sampling A nonstatistical sample of 16 out of 76 students were selected for Return to Title IV testing. Repeat Finding from Prior Year No Recommendation We recommend that procedures be reviewed to ensure that Return to Title IV calculations are accurately performed, and proper monitoring of information input into Colleague is implemented to ensure accuracy of data used in calculation of Title IV funds to be returned. Views of Responsible Individuals Management agrees with the finding.
Show full finding ▾Hide full finding ▴Finding 2019-002 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster (Federal Work Study, Federal Supplemental Educational Opportunity Grant, Federal Pell Grant, Federal Perkins Loan Program, Federal Direct Student Loan Program and Nurse Faculty Loan Program) CFDA: 84.033, 84.007, 84.063, 84,038, 84.268 and 93.264 Federal Award Number: P268K182273 Award Year: 2018/2019 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Compliance Requirement: Special Tests and Provisions ? Return to Title IV Criteria: The University is required to have procedures in place when a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement as in accordance with 34 CFR sections 668.22(a)(1) through (a)(5). Condition 16 of the 16 students tested had the incorrect calculation of Title IV funds to be returned upon withdrawal from the University. Upon further review by management, as a result of the original finding, it was noted that incorrect dates were used for the Spring semester calculations as well as some incorrect amounts for Fall and Spring semesters. Cause Designed internal controls over Return to Title IV calculation requirements were not followed as required by the University?s processes. Effect Without properly designed internal controls over Title IV calculation requirements, errors or omissions could occur affecting the accuracy of returned funds. Questioned Costs $26,597 Context/Sampling A nonstatistical sample of 16 out of 76 students were selected for Return to Title IV testing. Repeat Finding from Prior Year No Recommendation We recommend that procedures be reviewed to ensure that Return to Title IV calculations are accurately performed, and proper monitoring of information input into Colleague is implemented to ensure accuracy of data used in calculation of Title IV funds to be returned. Views of Responsible Individuals Management agrees with the finding.
Finding 2019-002 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster (Federal Work Study, Federal Supplemental Educational Opportunity Grant, Federal Pell Grant, Federal Perkins Loan Program, Federal Direct Student Loan Program and Nurse Faculty Loan Program) CFDA #84.033, 84.007, 84.063, 84,038, 84.268 and 93.264 Finding Summary: The University is required to have procedures in place when a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, to determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement as in accordance with 34 CFR sections 668.22(a)(1) through (a)(5). one of the original 16 students tested had the incorrect calculation of Title IV funds to be returned upon withdrawal from the University. Upon further review by management, as a result of the original finding, it was noted that incorrect dates were used for the Spring semester calculations as well as some incorrect amounts for Fall and Spring semesters. Corrective Action Plan (CAP): To ensure that all withdrawals are processed correctly and the Return to Title IV calculations are accurate, the Director of Financial Aid will detail review every Return to Title IV calculation in the University?s system (Colleague) and federal system (COD). The Director of Financial Aid and Associate Director of Financial Aid will also review all set-ups in the COD system to ensure accuracy of calendar set ups on which the calculations are dependent. Anticipated Completion Date: The corrective action plan will be implemented immediately.
FAC accepted this audit on September 13, 2018 — management decision was due March 13, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 5, 2017 — management decision was due March 5, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 22, 2016 — management decision was due March 22, 2017.
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