ARLINGTON BAPTIST UNIVERSITYHigher Education

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The University did not report enrollment and program information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 6 students were not reported correctly for campus enrollment, and 7 students were not reported correctly for program enrollment. All campus enrollments were corrected during the audit process. Cause: The University contracted with a third-party servicer to assist with enrollment reporting. For program enrollment, certain CIP codes were mapped to one code in NSLDS, which resulted in the students not being reported accurately. For the campus enrollment, three students were not reported as graduated, and three students were withdrawals and did not have the correct effective date reported. Of the six students who were not reported correctly for campus enrollment, three of them did not have any loans, so there was no impact on these students. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2024-001 Recommendation: We recommend the University work with the third-party servicer to properly map CIP codes and determine how campus enrollment data can be pulled out of the system to appropriately update NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: There was one incorrect calculation of a post withdrawal disbursement for a student that withdrew during the term. Two other students had the calculation performed correctly but an inaccurate amount returned. Criteria: 34 CFR 668.22 Questioned Costs: $32 Context: Out of 10 students, one student had an incorrect post withdrawal disbursement made, resulting in $32 more Pell disbursed to the student than was calculated. Two students had the correct calculations and the initial return on the student account did not match the calculation. Of these two, one was caught internally by the review process and corrected within the year, and one resulted in $26 of unsubsidized loans returned to the government that should not have been returned. Because the dollar amounts are small, the error rate is high, and this was a prior year finding this is classified as a significant deficiency. These students were corrected during the audit process. Cause: For the student with the post withdrawal disbursement, the calculation was done correctly, but the amount disbursed was $32 more than the calculation indicated, resulting in a required return to the government. One student had the correct calculation done but the incorrect amount returned which was noted at the end of the fall semester and corrected, returning an additional $96 of Pell. One student inadvertently returned the amount that was to be kept and resulted in $26 more being returned to the government than should have been. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Yes, 2024-002 Recommendation: We recommend the University add a step to verify attendance began at least half time for loan eligibility. We further recommend the University double check the amounts returned match the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 54 students tested, 45 students had incorrect enrollment statuses reported, of which seven were withdrawals. Additionally, out of 14 students tested, seven students had incorrect program reporting to NSLDS. Cause: The University’s process has been manual to update all NSLDS reporting by student. Effect: Inaccurate reporting can impact a student’s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2023-001 and 2022-002 Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 54 students tested, 45 students had incorrect enrollment statuses reported, of which seven were withdrawals. Additionally, out of 14 students tested, seven students had incorrect program reporting to NSLDS. Cause: The University’s process has been manual to update all NSLDS reporting by student. Effect: Inaccurate reporting can impact a student’s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2023-001 and 2022-002 Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns. Criteria: 34 CFR 668.22 Questioned Costs: $245 Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process. Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations. Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement. Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005. Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns. Criteria: 34 CFR 668.22 Questioned Costs: $245 Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process. Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations. Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement. Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005. Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not retain evidence or provide exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Out of 37 students tested for exit counseling, six students did not have any documentation of exit counseling being sent. The University is in the process of sending these students exit counseling notifications. Cause: These students were marked in the system as active, so they were not picked up with the report to send exit counseling. Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Official rates for 2020 and 2021 are listed at 0% due to COVID waivers. Identification as repeat finding, if applicable: Yes, 2023-003. Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not retain evidence or provide exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Out of 37 students tested for exit counseling, six students did not have any documentation of exit counseling being sent. The University is in the process of sending these students exit counseling notifications. Cause: These students were marked in the system as active, so they were not picked up with the report to send exit counseling. Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Official rates for 2020 and 2021 are listed at 0% due to COVID waivers. Identification as repeat finding, if applicable: Yes, 2023-003. Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Disbursements to Ineligible Students DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Two students who did not begin attendance in a semester were paid federal aid. Criteria: 34 CFR 668.32(a), 34 CFR 600.2 Questioned Costs: $9,500 Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end. Cause: The system check to verify attendance did not catch these students as not having begun the semester. Effect: Federal aid was paid to an ineligible student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Disbursements to Ineligible Students DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Two students who did not begin attendance in a semester were paid federal aid. Criteria: 34 CFR 668.32(a), 34 CFR 600.2 Questioned Costs: $9,500 Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end. Cause: The system check to verify attendance did not catch these students as not having begun the semester. Effect: Federal aid was paid to an ineligible student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 54 students tested, 45 students had incorrect enrollment statuses reported, of which seven were withdrawals. Additionally, out of 14 students tested, seven students had incorrect program reporting to NSLDS. Cause: The University’s process has been manual to update all NSLDS reporting by student. Effect: Inaccurate reporting can impact a student’s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2023-001 and 2022-002 Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 54 students tested, 45 students had incorrect enrollment statuses reported, of which seven were withdrawals. Additionally, out of 14 students tested, seven students had incorrect program reporting to NSLDS. Cause: The University’s process has been manual to update all NSLDS reporting by student. Effect: Inaccurate reporting can impact a student’s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2023-001 and 2022-002 Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns. Criteria: 34 CFR 668.22 Questioned Costs: $245 Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process. Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations. Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement. Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005. Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: There were four incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups and late notifications of students not attending, resulting in late returns. Criteria: 34 CFR 668.22 Questioned Costs: $245 Context: Out of 8 students, two students who withdrew during the audit period tested had funds returned late due to late notifications of non-attendance. Three students had incorrect calculations due to incorrect calendar set ups and needing to recalculate pell for classes the students began attendance in prior to performing the return calculation. This resulted in Pell owed back to the government of $78 and FDL owed back of $167 at fiscal year-end. Additionally, one student was not offered a post withdrawal disbursement of $292 of loans. Because the dollar amounts are small and the error rate is higher, this is classified as a significant deficiency. All students were corrected during the audit process. Cause: The calendar setups for fall 2023 were not set up properly. Additionally, notifications of nonattendance were not sent to financial aid timely to perform return calculations. Effect: Incorrect amount of unearned Title IV funds returned and lack of offering a post withdrawal disbursement. Identification as repeat finding, if applicable: Yes, 2023-002, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005. Recommendation: We recommend the University review the calendar set ups and ensure the proper number of days are used in the calculations. Additionally, we recommend the University implement a way to notify financial aid timely when students are not attending so a return calculation can be done timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not retain evidence or provide exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Out of 37 students tested for exit counseling, six students did not have any documentation of exit counseling being sent. The University is in the process of sending these students exit counseling notifications. Cause: These students were marked in the system as active, so they were not picked up with the report to send exit counseling. Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Official rates for 2020 and 2021 are listed at 0% due to COVID waivers. Identification as repeat finding, if applicable: Yes, 2023-003. Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not retain evidence or provide exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Out of 37 students tested for exit counseling, six students did not have any documentation of exit counseling being sent. The University is in the process of sending these students exit counseling notifications. Cause: These students were marked in the system as active, so they were not picked up with the report to send exit counseling. Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Official rates for 2020 and 2021 are listed at 0% due to COVID waivers. Identification as repeat finding, if applicable: Yes, 2023-003. Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Disbursements to Ineligible Students DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Two students who did not begin attendance in a semester were paid federal aid. Criteria: 34 CFR 668.32(a), 34 CFR 600.2 Questioned Costs: $9,500 Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end. Cause: The system check to verify attendance did not catch these students as not having begun the semester. Effect: Federal aid was paid to an ineligible student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Disbursements to Ineligible Students DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Two students who did not begin attendance in a semester were paid federal aid. Criteria: 34 CFR 668.32(a), 34 CFR 600.2 Questioned Costs: $9,500 Context: Out of 51 tested for eligibility, two students did not begin attendance in an eligible program. One student’s aid was returned prior to the end of the semester but beyond the allowable 30 days. The other student’s aid was returned shortly after fiscal year-end. Cause: The system check to verify attendance did not catch these students as not having begun the semester. Effect: Federal aid was paid to an ineligible student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University compare a listing of students who have begun attendance to federal aid paid and return any federal aid paid to ineligible students. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 57 students tested, 7 students had incorrect enrollment status reported, of which one student was an official withdrawal. Cause: The University’s process has been manual to update all NSLDS reporting by student. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2022-002. Recommendation: We recommend the University put a system in place to ensure that all students are being reported to NSLDS, and that the University is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There were 7 incorrect calculations of returned funds for students that withdrew during the term due to incorrect calendar setups. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 10 students, 7 students who withdrew during the audit period tested had incorrect funds returned due to incorrect calendar setups resulting in $254 of Pell and $185 of Federal Direct Loans returned more than required. Because of the error rate but immaterial dollar amounts, this is classified as a significant deficiency. Cause: The University uses a third party administrator to assist in processing R2T4’s. The third party administrator had incorrect calendar setups which resulted in all students completing less than 60% of the semester having an incorrect return. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001, 2021-003, 2020-006, 2019-005, and 2018-005. Recommendation: We recommend the University review the calendar setups and ensure the proper number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not retain evidence or providing exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $-0- Context: Out of 51 students tested for exit counseling, 2 students did not have any documentation of exit counseling being sent. These students were sent exit counseling notifications during the audit process. Cause: With transitions in financial aid counselors, documentation of notifying students was not available. Effect: Documentation of exit counseling was not available. Exit counseling packets assist in reducing the default rate. The official cohort default rate for the University was 5.5% in 2019, 20.5% in 2018, and 21.8% in 2017. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a process where all students leaving the University are notified of exit counseling requirements and documentation is retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Right to Cancel Notifications DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not consistently notified of their ability to cancel loan disbursements. Criteria: 34 CFR 668.165(a) Questioned Costs: $-0- Context: The templates used to notify students of upcoming loan disbursements did not include the instructions on how to cancel the loan. Cause: There was transition in the financial aid department and the templates used did not include the required language. Effect: There was noncompliance with the right to cancel notifications. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University update the template used for right to cancel notifications to include all required language. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew unofficially, the University did not always return the correct unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $2,580 Context: Out of six students tested, four students were unofficial withdrawals and two were official withdrawals. From the four unofficial withdrawals, one student was not identified as needing a return until the audit. This student is in the process of being corrected. Cause: The financial aid office had been notified the student had stopped attending two classes, but the student was still enrolled in more than half time hours. The financial aid office was not notified that the student did not have any passing grades in order to evaluate if a R2T4 would be required. This was due to changes in the registrar and short staffing at the University. Additionally, the initial return calculation did not include the appropriate number of days, and this was revised during the audit. Effect: The federal funding was not returned until the audit. Identification as repeat finding, if applicable: Yes 2021-003, 2020-006, 2019-005, and 2018-005 Recommendation: We recommend the University run a 0-credit report at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) for students who did not use federal funding while enrolled at the University. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 51 students tested, 1 student was not reported to NSLDS when they were enrolled more than half time at the University. This student had received federal funding previously but did not receive federal funding at the University. Cause: The University?s process has been to run a report of those with federal aid, and each of those students is then updated manually in NSLDS. Effect: The lack of reporting for a student who previously had received federal aid can impact the student?s loan grace period in school deferment eligibility and beginning loan repayments. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University put a system in place where all students that have received federal aid previously and are enrolled at the University are included on the report of students to report to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capacity Over the Student Financial Aid Program Material Weakness DEPARTMENT OF EDUCATION ALN #:84.268 and 84.063 - Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The administrative capability of the University was not adequate to properly maintain compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: Unknown Context: In our testing, we found multiple areas of noncompliance as detailed in Findings 2021-002 through 2021-010. Cause: Even though the University uses a third-party servicer for assisting with the administration of the financial aid programs, the financial aid administrator at the University and the third-party service did not share all required information timely in order to ensure compliance with Title IV regulations. Effect: Noncompliance with multiple Title IV regulations. Identification as repeat finding, if applicable: Yes: 2018-001, 2019-001, and 2020-001. Recommendation: We recommend the University financial aid administrator ensure adequate communication with the third-party servicer to encompass all needed information to process student financial aid correctly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Need Analysis and Estimated Financial Assistance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 - Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Students were not awarded the correct amount of need-based aid based on known estimated financial assistance and grade level. Criteria: 34 CFR 673.5(c), 34 CFR 685.200(a), 34 CFR 685.200(e), and 34 CFR 685.203(a) Questioned Costs: $9,569 Context: Out of 51 students who were tested for the appropriate need analysis, 4 students were not correctly awarded, and 1 student required a grade level adjustment. Two students did not have the institutional aid included as estimated financial assistance, resulting in federal direct loans over awarded in excess of cost of attendance by $5,819. 1 student didn?t have institutional aid included as estimated financial assistance and was over awarded subsidized loans by $1,211 which should have been allocated to unsubsidized loans and also over awarded Plus loans in excess of cost of attendance by $3,250. 1 student had a tuition waiver which was not included in need-based aid and required a reallocation of subsidized loans to unsubsidized loans in the amount of $971. Additionally, one student had a grade level adjustment resulted in subsidized loans over awarded by $500. The student with the grade level adjustment was corrected during the audit. Cause: Complete and correct information was not exchanged between the third-party servicer and the financial aid administer related to internal scholarships and grade level credits. Effect: Incorrect need analysis can cause students to be over awarded need-based aid or aid in excess of cost of attendance. Identification as repeat finding, if applicable: Yes: 2018-006, 2019-006, and 2020-004 Recommendation: We recommend the University implement procedures to ensure all changes in the scholarship package are shared with the third-party servicer and all awards that are internal and anticipated are added into estimated financial assistance. We also recommend the third-party servicer ensure the parameters for the appropriate grade levels are set up in the system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 - Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The University did not correctly and timely return all required federal funds when a student officially or unofficially withdrew. Criteria: 34 CFR 668.22 Questioned Costs: $4,463 Context: Out of 9 students tested for withdrawals, 2 students had incorrect R2T4?s performed resulting in $92 in FDL under returned for 1 student and $95 in Pell over returned for 1 student. 2 students had their Title IV funds returned late when determined as part of the audit process that an R2T4 was required. 1 of these students had $1,985 in FDL returned 197 days late. The other student had $2,386 in Pell returned 153 days late. Cause: There was incorrect communication between registrar and financial aid office as well as incorrect calendar setup by the third-party servicer. Effect: Late and incorrect returns of Title IV funds were noted. Identification as repeat finding, if applicable: Yes: 2018-005, 2019-005, and 2020-006 Recommendation: We recommend the University set up calendars correctly, implement review of calendar set up, communicate information with third-party servicer regarding critical dates and deadlines, and utilize the student?s last date of attendance instead of last absence reported for financial aid purposes to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2020-2021 Financial Aid Year Condition: NSLDS enrollment status effective date was not always accurate when reporting a change in enrollment status. Criteria: 34 CFR 685.309(b) Questioned Costs: $0 Context: Out of 54 students tested, 13 had incorrect effective dates for their enrollment status. Five withdrawals were incorrectly reported on the date of determination rather than on the last date of attendance. Three students were listed as withdrawn instead of graduated. Two enrollment summaries for spring 2021 were not reported until fall 2021 including one summary that lists the incorrect program enrollment for the student. One additional enrollment summary listed an incorrect program enrollment. One student was reported as having never attended yet the student was full-time during that semester. One student was reported as graduated when no degree was reported as conferred on the transcript. For the dates that were incorrectly used, the shortest was 5 days different and the longest was 70 days different. Cause: Manual updates were being performed between program enrollment and detail enrollment and did not capture some enrollment status changes which were tied to payments being made. For unofficial and official withdrawals, the last date of attendance was not consistently used to update the NSLDS. Effect: For students who withdrew or graduated, this error can cause the students to lose all or part of their 6-month grace period. Inaccurate or late reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes: 2017-001, 2018-003, 2019-003, and 2020-002. Recommendation: We recommend the University use the batch upload process in the system to ensure completeness and accuracy of student enrollment reporting. We also recommend the University spot check the first few uploads to ensure they are functioning properly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley-Act Compliance (GLBA) Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063 Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314 Questioned Costs: $0 Context: The University has not sufficiently documented its security risk assessment and related safeguards. Cause: The University has not allocated sufficient resources to address the requirements of GLBA. IT operations were also impacted by COVID-19. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes: 2020-003. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

Incorrect Dates Noted on Pell Common Origination and Disbursement (COD) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The University did not report Pell distribution dates correctly. Criteria: 34 CFR 668.164(a) Questioned Costs: $0 Context: Out of 84 disbursements tested, 19 dates reported to COD did not contain correct Pell distribution dates. The disbursements tested were 43 in fall 2020, 40 in spring 2021, and 1 in summer 2021. The most pervasive error was in January 2021, and the dates reported to COD were between 7 and 20 days different, but all fell within the month of January. Cause: There was miscommunication between third party and business office on date applied. Effect: There is the potential for students to receive Pell awards in excess of the aggregate or annual limits in the event student transfers schools during the award year. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University perform required student by student monthly reconciliations of Pell. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Late Disbursement Not Offered or Made DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grant Federal Award Identification #: 2020-2021 Financial Aid Year Condition: A disbursement was not offered or made timely for 1 student who was eligible for federal aid. Criteria: 34 CFR 668.60(c)(1), 34 CFR 690.61(b)(1), 34 CFR 668.164(j)(1)(ii) Questioned Costs: $0 Context: Out of 51 students tested, one student was not offered or paid federal aid, even though they met the qualification of late disbursement, since the student was still enrolled at the time verification was completed in January 2021. At the time the school identified the issue, the late disbursement period had passed. Cause: There was an incorrect interpretation of guidance related to disbursements and timing of verifications. Effect: There was an incorrect amount of aid awarded to the student based on their eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University review guidance related to late disbursements to ensure accuracy in financial aid awards when verification is completed later than normal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Verification Not Performed Accurately DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 - Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Verification was not accurately completed on 2 students who received federal aid. Criteria: 34 CFR 668.56 Questioned Costs: Unknown Context: Out of 25 students tested for eligibility and disbursement testing, 2 students were not appropriately verified with updates being processed to their ISIR. Cause: Third-party servicer did not correctly update the adjusted gross income for one student. For the other student, changes were not recorded related to discrepancies in income noted during the verification process. Effect: The students may not receive the correct amount of federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University verify all required information and submit all required changes to the ISIR during the verification process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Required Resolution Not Completed for Code 400 DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 - Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Resolution of ISIR code 400 was not completed for 2 students prior to awarding financial aid. Criteria: 2020-2021 SAR Comment Codes and Text; August 7, 2017 Electronic Announcement Questioned Costs: $0 Context: Out of 51 students tested for resolution of potential ISIR flags, two students with ISIR flags for code 400 did not receive appropriate and required resolution. Required resolution of ISIR codes was waived by the third party administrator because the parent taxes were linked to the FAFSA. For one student, the earned income was greater than the adjusted gross income. Cause: There was a lack of understanding of the August 7, 2017 Electronic Announcement. Effect: The incorrect amount of aid could be awarded to the student based on an inaccurate ISIR. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University complete resolution of all ISIR flag code 400 that require follow-up. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Exit Counseling Not Provided DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Required student exit counseling was not performed. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Of 22 students tested, 2 students did not receive required exit counseling after leaving the University. For one student, the exit notice was sent five months following the student leaving the University, and for the other student, the exit counseling notification was sent eight months following the student leaving the University. Cause: There was a lack of timely tracking of students exiting and the required communication. Effect: Lack of timely exit counseling can lead to increased borrower default which can contribute to a higher default rate with additional administrative burden to the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University complete exit counseling notifications each semester for students who withdraw or move to an enrollment status of less than half time. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

2020-001 Administrative Capability Over the Student Financial Aid Program Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 and 84.063 (Student Financial Aid Cluster) Federal Award Identification #: 2019-2020 Financial Aid Year Condition: The administrative capability of the University was not adequate to properly maintain compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: Unknown Context: In our testing, we found multiple areas of noncompliance as detailed in Findings 2020-002 through 2020-006. Effect: Noncompliance with a number of Title IV regulations. Cause: Even though the University uses a third party administrator for assisting with the administration of the financial aid programs, the financial aid administrator at the University during the period under audit did not possess adequate skills and knowledge to ensure compliance with Title IV regulations. The financial aid administrator did change near the fiscal year-end. Identification as repeat finding, if applicable: Yes, 2018-001 and 2019-001. Recommendation: We recommend that the University provide adequate support to the new financial aid administrator to ensure that this important role is properly staffed with the necessary skills, knowledge, and expertise. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

2020-002 Incorrect Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: NSLDS enrollment status effective date was not always accurate when reporting a change in enrollment status. Criteria: 34 CFR 685.309(b) Questioned Costs: $0 Context: Out of 51 students tested, 6 had incorrect effective dates reported for their enrollment status. Withdrawals were not reported as withdrawn on their last date of attendance. Graduation dates were reported incorrectly. All students were corrected during the audit. Cause: Financial aid administrator was manually updating some enrollment status changes but failed to leave the previous information providing appropriate deferrals. For unofficial and official withdrawals, the last date of attendance was not consistently used to update NSLDS. Effect: For students who withdrew or graduated, this error caused the students to lose all or part of their 6-month grace period. Inaccurate or late reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: 2017-001, 2018-003, and 2019-003 Recommendation: We recommend that the financial aid administrator review the NSLDS Enrollment Reporting Guide and fully understand the different components of NSLDS enrollment reporting to ensure accuracy. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

2020-003 Gramm-Leach-Bliley-Act Compliance (GLBA) Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314 Questioned Costs: $-0- Context: The University has not sufficiently documented its security risk assessment and related safeguards. Cause: The University has not allocated sufficient resources to address the requirements of GLBA. IT operations was also impacted by COVID-19. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

2020-004 Need Analysis and Estimated Financial Assistance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: Need based awards were done in conjunction with the third-party servicer based on cost of attendance, expected family contribution, and other institutional aid. Three students out of 51 were not initially awarded the correct amount of loans based on need. Additionally, one student was not awarded the correct amount of subsidized loans based on the year of enrollment. Criteria: 34 CFR 673.5(c), 34 CFR 685.200(a), 34 CFR 685.200(e), and 34 CFR 685.203(a) Questioned Costs: $0 ? just reallocations between subsidized loans and unsubsidized loans. Context: Out of 51 students who were tested for the appropriate need analysis, 4 students were not correctly awarded. Two students did not have the institutional aid included as estimated financial assistance, resulting in subsidized loans over need by $4,090. Two students were not offered subsidized loans when there was need of $1,000. Cause: There was not complete information exchanged between the third-party servicer and the financial aid administer. Effect: Inaccurate need analysis can cause students to be over awarded need-based aid or aid in excess of cost of attendance. Identification as repeat finding, if applicable: 2018-006 and 2019-006 Recommendation: We recommend that procedures be implemented to review the detailed transaction document for scholarship discounts posted and compare to financial resources used in the need analysis computation to ensure all estimated financial assistance is appropriately considered and Title IV properly awarded. We further recommend a per semester report be run to need based aid to accepted aid and ensure all students are properly awarded based on year of enrollment. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

2020-005 Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.063 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: Out of 25 students tested, 2 students were not properly awarded Pell based on the enrollment status and classes in which they began attendance. Criteria: 34 CFR 690.63(b) and 34 CFR 668.164(b)(3) Questioned Costs: $0 Context: One student was awarded as half time when the student had added a class and the third-party servicer was not informed of the addition which resulted in an underaward of $681. One student was flagged on the ISIR for close to the Pell lifetime eligibility limits and was incorrectly calculated for remaining eligibility resulting in an underaward of $50. Cause: For one student, the information was not shared when a class was added. For the other student, there was a mathematical error. Effect: Students were awarded financial aid incorrectly based on classes they began. Identification as repeat finding, if applicable: 2019-002 Recommendation: We recommend the University run a report during each semester to verify that changes in enrollment status are captured. We further recommend the University perform a review of mathematical calculations for those students close to the lifetime limits. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

2020-006 Late Return for Unofficial Withdrawal DEPARTMENT OF EDUCATION CFDA #: 84.268 and 84.063 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: The University did not properly monitor for unofficial withdrawals and was not timely in returning unearned Title IV funds for a student who unofficially withdrew from the fall 2019 semester. Criteria: 34 CFR 668.22(b) (2) and 34 CFR 668.22 (j) (1) Questioned Costs: Unknown Context: There were 4 students who received all F?s and unofficially withdrew during the year. As part of the audit process, we tested all 4 of these students, and it was determined that one of these students did stop attending and should have had an R2T4 completed. The University was unable to determine the last date of attendance in order to perform the return calculation. Cause: Inadequate procedures for monitoring for unofficial withdrawals. The University tracks the date the student accumulates their 8th absence but not does provide the last date of attendance to the financial aid administrator. Lack of communication and follow up with the registrar?s office on students who do not have any passing grades at the end of a term. Effect: Late return of unearned Title IV funds and non-compliance with regulations requiring timely determination for unofficial withdrawals. Identification as repeat finding, if applicable: 2018-005 and 2019-005 Recommendation: We recommend that the University work with the registrar?s office to implement better procedures for monitoring unofficial withdrawals and completing timely R2T4?s when required for students who unofficially withdraw during a term. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-001 Administrative Capability Over the Student Financial Aid Program Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 and 84.063 (Student Financial Aid Cluster) Federal Award Identification #: 18-19 Financial Aid Year Condition: The administrative capability of the University was not adequate to properly maintain compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $33,611 Context: In our testing, we found multiple areas of noncompliance as detailed in Findings 2019-002 through 2019-009. Effect: Noncompliance with a number of Title IV regulations. Cause: Even though the University uses a third party administrator for assisting with the administration of the financial aid programs, the financial aid administrator at the University does not possess adequate skills and knowledge to ensure compliance with Title IV regulations. Identification as repeat finding, if applicable: Yes, 2018-001. Recommendation: We recommend that the University re-evaluate the financial aid administrator position and determine what steps need to be taken to ensure that this important role is properly staffed with the necessary skills, knowledge and expertise. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-002 Incorrect Pell Calculations Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.063 Federal Award Identification #: 18-19 Financial Aid Year Condition: Out of 30 students tested, 3 students were not properly awarded Pell based on the enrollment status and expected family contribution and classes that they began attendance in. Criteria: 34 CFR 690.63(b) Questioned Costs: $4,979 Context: One student was awarded as half time using an incorrect expected family contribution, which led to an overaward of Pell of $1,170. Two students were scheduled to begin attendance classes and did not begin attendance, which required the Pell to be returned for those students. Effect: Students were awarded financial aid incorrectly based on classes they begun and their expected family contribution. Cause: For one student, an incorrect expected family contribution was used. For the other students, the University failed to document whether the student had begun attendance. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University run a report each semester to verify the correct EFC is used for awarding Pell. We further recommend the University document whether students have begun attendance in each class and promptly return funds where the students did not begin. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-003 Incorrect Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 18-19 Financial Aid Year Condition: NSLDS enrollment status effective date was not always accurate when reporting a change in enrollment status. Criteria: 34 CFR 685.309(b) Questioned Costs: $0 Context: Out of 55 students tested, 25 had incorrect effective dates reported for their enrollment status. Withdrawals were not reported as withdrawn on their last date of attendance. 8 students were not reported as enrolled during the fall semester when they were enrolled half time or more. 5 students were not reported as enrolled during the spring semester when they were enrolled half time or more. Graduation dates were reported incorrectly. Effect: For students who withdrew or graduated, this error caused the students to lose all or part of their 6 month grace period. Inaccurate or late reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan payments, appropriate interest charges, etc. Cause: Financial aid administrator was manually updating some enrollment status changes but failed to leave the previous information providing appropriate deferrals. For unofficial and official withdrawals, because the returns were late, the updates to NSLDS were also not done correctly or timely. Identification as repeat finding, if applicable: 2017-001 and 2018-003 Recommendation: We recommend that the financial aid administrator review the NSLDS Enrollment Reporting Guide and fully understand the different components of NSLDS enrollment reporting to ensure accuracy. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-004 Inaccurate Reporting to Common Origination and Disbursement (COD) Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063 Federal Award Identification #: 18-19 Financial Aid Year Condition: The Federal Direct Loan (FDL) disbursement dates reported to COD did not always agree to the actual date the disbursements were posted to the student?s account. Additionally, the Pell COD dates did not always agree to the actual date the disbursements were posted to the student?s account. Criteria: 34 CFR 668.164(a) and Chapter 4, Volume 5 of the FSA Handbook Questioned Costs: $0 Context: For 13 out of 47 students tested, the FDL date disbursed as reported in COD did not agree to the date the loan funds were actually disbursed to the student?s account. The reporting errors ranged from 6 days to 254 days. 3 out of 30 students tested for Pell COD dates were incorrect, ranging from 8 to 35 days. We noted that monthly reconciliations are being completed, so it appears that something in the reconciliation process is not working as intended. Effect: Inaccurate disbursement dates affects the amount of interest repayment by the student and creates additional reconciling items for monthly FDL reconciliations. Cause: Miscommunication with third party administrator. Identification as repeat finding, if applicable: 2018-004 Recommendation: We recommend the University work with the third party administrator to correct disbursement dates in COD when there is a difference between originally reported disbursement dates and when those disbursements are actually posted to a student?s account. We further recommend a monthly reconciliation be completed that includes year to date information to capture any changes made in prior periods. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-005 Late Return for Unofficial Withdrawals and Official Withdrawals Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 18-19 Financial Aid Year Condition: The University did not properly monitor for unofficial withdrawals and was not timely in returning unearned Title IV funds students who unofficially withdrew from the spring 2019 semester. Additionally, there was one official withdrawal in the fall 2018 semester that was not returned timely. Criteria: 34 CFR 668.22 (j) (1) Questioned Costs: $15,438 Context: There were 9 students who received all F?s and unofficially withdrew during the year. As part of the audit process, we tested 7 of these students, and it was determined that four of these students did stop attending and should have had an R2T4 completed. The University has since completed the R2T4s and returned the $15,438 of FDL in September 2019. These were corrected during the audit process. Effect: Late return of unearned Title IV funds and non-compliance with regulations requiring timely determination for unofficial withdrawals. Cause: Inadequate procedures for monitoring for unofficial withdrawals. The University tracks the date the student accumulates their 8th absence but not does provide the last date of attendance to the financial aid administrator. Lack of communication and follow up with the registrar?s office on students who do not have any passing grades at the end of a term. Identification as repeat finding, if applicable: 2018-005 Recommendation: We recommend that the University work with the Registrar office to implement better procedures for monitoring unofficial withdrawals and completing timely R2T4?s when required for students who unofficially withdraw during a term. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-006 Need Analysis and Estimated Financial Assistance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 and 84.063 Federal Award Identification #: 18-19 Financial Aid Year Condition: Need based awards were done in conjunction with the third party servicer based on cost of attendance, expected family contribution, and other institutional aid. Three students out of 51 were not initially awarded the correct amount of loans based on need. Criteria: 34 CFR 673.5(c), 34 CFR 685.200(a), and 34 CFR 685.200(e) Questioned Costs: $401 Context: Out of 51 students who were tested for the appropriate need analysis, 3 students were not correctly awarded. 1 student did not have the institutional aid included as estimated financial assistance, resulting in subsidized loans over need by $990. One student was not offered subsidized loans when there was need of $1,913. One student was awarded over the cost of attendance by $401. These were corrected during the audit process. Effect: Inaccurate need analysis can cause students to be over awarded need based aid or aid in excess of cost of attendance. Cause: There was not complete information exchanged between the third party servicer and the financial aid administer. Identification as repeat finding, if applicable: 2018-006 Recommendation: We recommend that procedures be implemented to review the detailed transaction document for scholarship discounts posted and compare to financial resources used in the need analysis computation to ensure all estimated financial assistance is appropriately considered and Title IV properly awarded. We further recommend a per semester report be run to need based aid to accepted aid and ensure all students are properly awarded. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-007 Failure to Meet Satisfactory Academic Progress Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.063 Federal Award Identification #: 18-19 Financial Aid Year Condition: Two students were awarded aid when the student had not met satisfactory academic progress requirements. Criteria: 34 CFR 668.32(f) Questioned Costs: $12,793 Context: Out our sample of 35 students who were tested for meeting academic progress, we noted three students who had not met the requirements and were awarded federal funds. One student had not attended school for multiple years but had not been meeting SAP when they last attended and did not complete an appeal. Two students were disbursed aid and noted in the audit process that they were not eligible. These were corrected during the audit process. Effect: Lack of reviewing incoming satisfactory progress led to an overaward of federal aid. Cause: The previous academic progress was not checked prior to awarding the student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that procedures be implemented to satisfactory academic progress is tested for all students prior to awarding funds. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-008 Awarding Over Aggregate Limits DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 18-19 Financial Aid Year Condition: One student was awarded subsidized loans over the aggregate limit. Criteria: 34 CFR 685.203(d) Questioned Costs: $0 Context: Out of 10 students in our sample of 51 students who were tested for being near the aggregate loan limits, 1 student was awarded and received subsidized loans in excess of the aggregate limit by $3,500. The student had not yet reached the aggregate unsubsidized loan limits, meaning these funds can be reallocated to unsubsidized loans to avoid questioned costs. This was corrected during the audit process. Effect: Incorrect resolution of the ISIR codes led to an overaward of subsidized loans. Cause: There was not complete information exchanged between the third party servicer and the financial aid administer. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that procedures be implemented to ensure all ISIR codes are properly resolved and additional awarding after the resolution is not above aggregate limits. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-009 Failure to Wait 30 Days to Disburse Loan Funds DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 18-19 Financial Aid Year Condition: One student did not properly have the 30 day delay for the first time borrower. Criteria: 34 CFR 685.303(b)(5)(i) Questioned Costs: $0 Context: Out our sample of 34 students who were tested for disbursement dates, 8 students required the 30 day delay. We noted one student who did not meet the 30 day delay requirement; this student received a disbursement 8 days after the start of the semester. Effect: Noncompliance with 30 day delay rule. Cause: Inadequate procedures to force the 30 day delay. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that procedures be implemented to ensure all first time borrowers are appropriately delayed in their first disbursement. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION