FINDING 2022-001: MISSING PROOF OF LOAN ENTRANCE COUNSELING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2022 Compliance Requirement: Eligibility (E.) Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement (34CFR 682.604, 685.304). Condition: We tested thirty-seven files, twenty-seven of which were Federal Direct Loan recipients, and noted one student missing entrance counseling. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result of not conducting entrance counseling is students may be uninformed about the responsibilities and consequences of borrowing funds. Question Costs: $5,541 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution improve controls over retaining documentation on entrance interviews. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comments on Findings and Recommendations: 2022-001 - Missing Proof of Loan Entrance Counseling. It seems that the student may not have completed entrance counseling. When this student started, MCU was contracted with Weber as its Third- Party Servicer who used to check entrance counseling before processing our students. Since 2020, MCU has been contracted with Campus Ivy whose platform now requires the Financial Aid Department to upload the entrance counseling proof before processing can occur. B. Actions Taken or Planned: 2022-001 - Missing Proof of Loan Entrance Counseling. The student in question has now performed the required Entrance Counseling. Since May 2020, MCU's updated entrance counseling process with Campus Ivy has helped mitigate a risk of gaps with regard to the completion of entrance counseling. MCU will perform an internal review on current students enrolled before May 2020 to ensure entrance counselings are complete.
FINDING 2022-002: INCORRECT REFUND CALCULATIONS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2022 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds (N.) Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested thirteen drop students and found two incorrect refund calculation. We consider this finding to be a significant deficiency. This is a repeat of prior year Finding 2021-003. Cause: The condition was caused by not properly adjusting days for a break at Step 2 of the Return to Title IV refund calculation. Effect: The result is the Institution returned funds to the Department of Education that should have been retained by the Institution. Question Costs: $0 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution credit $304 to the students' accounts and tighten controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comments on Findings and Recommendations: 2022-002 - Incorrect Refund Calculations. This seems like a simple administrative error surrounding the break and that the break should have been included. The Financial Aid Operations Administrator was still in their final R2T4 training phase at this point in 2022, having taken on the task during the prior year. B. Actions Taken or Planned: 2022-002 - Incorrect Refund Calculations. The Financial Aid Department has updated their internal procedures for R2T4's to make them even more robust, adding further emphasis on the scheduled trimester break section within its R2T4 template. This should help further mitigate the risk of mix up when performing a few at the same time. MCU will refund the resulting overage to the student.
2021-003
FINDING 2022-003: INACCURATE ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM, FEDERAL DIRECT LOAN PROGRAM ALN#: 84.063, 84.268 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2022 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: The Institution did not provide enrollment update responses in a timely manner for one student who graduated. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Department of Education was not made aware of the changes in student statuses in a timely manner. Question Costs: $0 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution tighten controls enrollment reporting. As this was an isolated incident, we are issuing a non-compliance finding. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comments on Findings and Recommendations: 2022-003 - Untimely Enrollment Status Reporting. The Financial Aid Department has a consistent procedure surrounding NSLDS updates, but like many schools, encountered some technical issues over the summer when the NSLDS platform was updated. B. Actions Taken or Planned: 2022-003 - Untimely Enrollment Status Reporting. MCU switched over to Campus Ivy performing its NSLDS reporting in December 2022 which helps eliminate the duplication of efforts in updating CORE and NSLDS. This should also help to close any potential gaps in reporting.
FINDING 2021-001: OVERAWARDED FEDERAL DIRECT LOANS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2021 Compliance Requirement: Eligibility (E.) Criteria: A third year student can receive up to $5,500 in subsidized loans and $7,000 in unsubsidized loans in one academic year (34 CFR 685.203). Condition: We tested thirty-seven files, twenty-four of which were Federal Direct Loan recipients, and one student received loans in excess of need. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is a student received ineligible loan proceeds. Question Costs: $266 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution return $266 to the Department of Education and increase controls over Federal Direct Loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comment on Findings and Recommendations MCU acknowledges that instead of 23.13/24, it appears that the proration performed was 23.64/24, seems like a data entry error. B. Actions Taken or Planned: MCU plans on returning $266 dollars in order to correct the over-award.
FINDING 2021-002: INCOMPLETE VERIFICATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2021 Compliance Requirement: Eligibility (E.) Criteria: An institution shall require each student whose application is selected for verification to verify all of the applicable items specified (34 CFR 668.54). Condition: We tested thirty-seven files and an application selected for verification did not match supporting documentation for one student. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by using an incorrect number of family members when filling out the Free Application for Federal Student Aid (FAFSA). Effect: The result of not properly verifying a student?s Institutional Student Information Report (ISIR) to supporting documentation is the student received an unauthorized award. Question Costs: $174 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution refund $174 to the Department of Education and increase controls over verification. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comment on Findings and Recommendations MCU acknowledges that the ISIR required updating. B. Actions Taken or Planned Upon MCU?s request, its third-party servicer updated the ISIR. It resulted in a return of $176 for the student?s 11/24/2020 disbursement & $174 for their 06/15/2021disbursement. Both returns are complete.
FINDING 2021-003: INCORRECT REFUND CALCULATIONS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2021 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds (N.) Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested fourteen drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by not properly adjusting days for a break at Step 2 of the Return to Title IV refund calculation. Effect: The result is the Institution returned funds to the Department of Education that should have been retained by the Institution. Question Costs: $0 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: There is no liability as the Institution over refunded loans. We recommend the Institution tighten controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comment on Findings and Recommendations MCU agrees that the break appears to be missing from the R2T4 calculation. B. Actions Taken or Planned MCU plans on requesting $92 back to account for the error in the calculation.
FINDING 2021-004: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2021 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds (N.) Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested fourteen drop students and note one late refund. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by the Institution correcting the refund calculation, which led to a portion of the refund being returned late. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $331 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution tighten controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comment on Findings and Recommendations MCU acknowledges that a portion of the student?s refund was late due to a correction on the R2T4.B. Actions Taken or Planned MCU has tightened its controls around completions of R2T4s, creating a buffer in the timing in order to allow for additional review.
FINDING 2021-005: UNTIMELY ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM, FEDERAL DIRECT LOAN PROGRAM ALN#: 84.063, 84.268 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2021 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: The Institution did not provide enrollment update responses in a timely manner for November 2021. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Department of Education was not made aware of the changes in student statuses in a timely manner. Question Costs: $0 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for table. Recommendation: We recommend the Institution tighten controls enrollment reporting. As this was an isolated incident, we are issuing a non-compliance finding. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
A. Comment on Finding and Recommendations MCU acknowledges that it appears that November was not updated within the 15 day requirement. B. Actions Taken or Resolved MCU has created a control around the timing of enrollment reporting by committing it to the department?s coverage plan and calendar bringing it in line with other department milestones and routinely reviewed by the Director of Financial Aid.
FINDING 2020-001: UNDERAWARDED PELL GRANTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM CFDA#: 84.063 FEDERAL AWARD YEAR: YEAR ENDED DECEMBER 31, 2020 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, twenty-two of which were Pell Grant recipients, and one student did not receive the full amount of her allowed Pell grants. The student was eligible for $3,831, but received $2,630. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an incorrect proration of weeks, when credits should have been used to prorate the Pell Grants. Effect: The result is a student did not receive $1,201 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. Students Pell Direct Loan Total Universe 172 $411,850 $693,559 $1,105,409 Sample 37 71,982 158,209 230,191 Finding 1 (1,201) - (1,201) Recommendation: As $581 has since been credited to the student's account, we recommend the Institution credit the remaining $620 to the student's account and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
MCU has already credited $581 in Pell from the 19-20 award year and MCU agrees that the student is due $620 in Pell from the 18/19 award year and has requested those funds to be scheduled by its third-party servicer. MCU will add an additional control around the communication of graduation date updates to the Financial Aid Department to better ensure accuracy surrounding proration.
FINDING 2019-002: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Eligibility (E.) Criteria: A third-year student can receive up to $5,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested thirty-seven files and one student did not receive the full amount of her Federal Direct Subsidized Loan. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year finding 2018-001. Cause: The condition was caused by an oversight in the financial aid department. Effect: The student received $1,375 of Unsubsidized Federal Direct Loans which should have been Subsidized Federal Direct Loans. Question Costs: ($1,375) Statistical sampling was not used when making sample selections. Students Pell Direct Loan Total Universe 159 $362,469 $632,066 $994,535 Sample 37 90,829 141,355 232,184 Finding 1 - (1,375) (1,375) Recommendation: We recommend the Institution reclassify $1,375 from unsubsidized to subsidized and increase controls over packaging loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Midwives College of Utah's Financial Aid Department will incorporate an additional step in its review process of the payment lists from its third-party servicer to better ensure accuracy. The Financial Aid Department will reclassify $1,375 from unsubsidized to subsidized.
2018-001
FINDING 2019-003: INACCURATE ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 & 2019-2020 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: We tested thirty-seven files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for seven students. We consider this finding to be a significant deficiency. Cause: The condition was caused by various oversights in the financial aid department. Effect: The result is students? enrollment dates were reported to NSLDS inaccurately or were missing. Question Costs: $0 Statistical sampling was not used when making sample selections. Students Pell Direct Loan Total Universe 159 $362,469 $632,066 $994,535 Recommendation: As effective dates have since been updated in NSLDS, we recommend the College increase controls over enrollment reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Midwives College of Utah's Financial Aid Department will seek additional training and create an additional control around NSLDS reporting to better ensure accurate reporting.
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