EIN: 756002129
UEI: YB44K4RPL8K4
Audited by: WHITLEY PENN LLP
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 January 8, 2026. 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 July 8, 2026 (51 days ago).
What is a management decision? →In our test of Disbursements to or on Behalf of Students, 24 of 40 students in our sample received Direct Loans. Of these 24 students who received Direct Loans, 10 students were not notified within 30 days, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the District that he or she wishes to cancel the loan. Cause: The notifications were not sent to students due to an oversight by a former employee. Effect: The notification requirement is designed to protect borrowers by ensuring transparency and choice. Without this notification, students may be unaware of their right to cancel loans, leading to increased loan balances and repayment obligations. Questioned Costs: None reported Repeat Finding: No Recommendation: Implement internal controls and compliance reviews to ensure timely notifications to students. Conduct mandatory training for financial aid staff on updated procedures and system functionality. Implement periodic internal audits to verify that notifications are sent timely and documentation is retained in student files. Views of Responsible Official: Refer to corrective action plan.
Show full finding ▾Hide full finding ▴III - Federal Award Findings and Questioned Costs #2025-001 Federal Program: Student Financial Aid Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Compliance Requirement: N. Special Tests and Provisions – 3. Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency and Compliance Criteria: When Direct Loans are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the District that he or she wishes to cancel the loan (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loans. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition: In our test of Disbursements to or on Behalf of Students, 24 of 40 students in our sample received Direct Loans. Of these 24 students who received Direct Loans, 10 students were not notified within 30 days, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the District that he or she wishes to cancel the loan. Cause: The notifications were not sent to students due to an oversight by a former employee. Effect: The notification requirement is designed to protect borrowers by ensuring transparency and choice. Without this notification, students may be unaware of their right to cancel loans, leading to increased loan balances and repayment obligations. Questioned Costs: None reported Repeat Finding: No Recommendation: Implement internal controls and compliance reviews to ensure timely notifications to students. Conduct mandatory training for financial aid staff on updated procedures and system functionality. Implement periodic internal audits to verify that notifications are sent timely and documentation is retained in student files. Views of Responsible Official: Refer to corrective action plan.
Corrective Action Plan 1. Implement Automated Notifications (New and Long-Term Solutions) The institution will establish a two-phase approach to ensure timely and compliant Title IV disbursement notifications. New Process: A weekly report will be generated for Title IV loan disbursements with the corresponding notifications sent to students. Financial aid staff will review the report to confirm that each required notification was issued within the regulatory timeframe. Any missing notifications will be immediately sent and documented. This interim process will remain in effect until full automation is implemented. Long-Term Automated Solution: The student information system will be configured to automatically generate and send Title IV disbursement notifications to students. Each notification will be sent no earlier than 30 days before, and no later than 30 days after, the crediting of Title IV loan funds to the student’s ledger account, as required by 34 CFR §668.165(a)(2). The system will also store a timestamped record of each notification in the student’s electronic file for audit and compliance verification. 2. Develop Written Procedures A formal institutional policy and procedural guide will be developed to define the timing, content, and method of Title IV disbursement notifications. This documentation will explicitly address regulatory requirements under 34 CFR §668.165(a) and outline staff responsibilities for monitoring and documentation. 3. Staff Training Financial Aid staff will receive training on the new automated notification process, including policy updates, system functionality, and documentation requirements. Completion of training will be tracked to ensure all relevant personnel are fully informed and able to implement the new procedures consistently. 4. Periodic Compliance Reviews Quarterly internal audits will be conducted to confirm that required notifications are being issued as scheduled and properly documented in each student’s record. Any discrepancies identified will result in immediate corrective measures and additional staff coaching as needed. Responsible Party Director of Financial Aid Timeline for Completion - New System Implementation: Immediate - Long-Term Solution: Work with software provider and IT for options to implement this process - Policy Documentation & Staff Training: Within 90 days - First Compliance Review: Within 90 days
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