EIN: 936001786
UEI: YDTVUWXQAZK9
Audited by: CLIFTONLARSONALLEN LLP
Oversight agency: 84 [Department of Education]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2024. 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 September 30, 2024 (708 days ago).
What is a management decision? →During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance: 8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)) 1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)) Questioned costs: None Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above. Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat Finding: No Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063; 84.268; 84.007 Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303). Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). We identified the following items of noncompliance: 8 enrollment changes where a student's enrollment status effective date was not correctly reported to NSLDS. (34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)) 1 instance where a student’s enrollment status change was not reported timely to NSLDS. (34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)) Questioned costs: None Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 9 instances with exceptions as described above. Cause: The University was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat Finding: No Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure enrollment reporting and monitoring of third-party service providers results in accurate and timely reporting by the third-party service provider. While the third-party service provider has a national monopoly on enrollment reporting, with other institutions of higher education also facing similar reporting issues by the third-party service provider, Management believes that enhanced training and internal procedures over enrollment reporting will mitigate accuracy and timeliness errors made by the third party service provider, resulting in the University meeting U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: June 30, 2024
During our testing of outstanding SFA checks, we identified three checks outstanding that had not been returned to the U.S. Department of Education within 240 days. Questioned costs: None Context: Out of our population of 31 outstanding checks, we noted three had the exception described above. Cause: The University did not have a process in place when these checks were created in fiscal year 2021; when a process was created, it was not retroactively applied to all outstanding SFA checks to date. Effect: The University did not return all SFA funds timely to the Department of Education. Repeat Finding: No Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K32067, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.164(l) requires an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution. Additionally, if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303). Condition: During our testing of outstanding SFA checks, we identified three checks outstanding that had not been returned to the U.S. Department of Education within 240 days. Questioned costs: None Context: Out of our population of 31 outstanding checks, we noted three had the exception described above. Cause: The University did not have a process in place when these checks were created in fiscal year 2021; when a process was created, it was not retroactively applied to all outstanding SFA checks to date. Effect: The University did not return all SFA funds timely to the Department of Education. Repeat Finding: No Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures regarding stale-dated federal student financial aid outstanding checks. Management will implement additional procedures, returning checks issued directly by the University that stale-dated, similar to policies and procedures followed by the University’s third-party credit balance refund vendor. As part of this procedure, management will engage in student communication and outreach, similar to the University’s regular escheatment procedures. Management believes that a consistent practice between University-issued checks and third-party credit balance refund vendor-issued checks is in the best interest of students while also adhering to U.S. Department of Education timing requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024
During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education. Questioned costs: None Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education. Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed. Effect: The U.S. Department of Education was not provided required information regarding the contract. Repeat Finding: No Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063; 84.268; 84.007 Federal Award Identification Number and Year: P063P222067, P268K32067, P007A223499; 2022- 2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.164(e)(2)(viii) requires institutions must provide an upto-date URL for their contract with a third-party servicer who assist in providing credit balances to students. This publication is published in a centralized database accessible to the public managed by the U.S. Department of Education. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303). Condition: During our testing the University could not provide support that an up-to-date third party servicer contract and the related contract data was provided to the U.S. Department of Education. Additionally, the University was not included within the database retained by the U.S. Department of Education. Questioned costs: None Context: The University did not meet the compliance requirement to report the contract and contract components to the U.S. Department of Education. Cause: The University was not aware of the requirement and previous personnel did not retain applicable support, if completed. Effect: The U.S. Department of Education was not provided required information regarding the contract. Repeat Finding: No Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all required information is provided to the U.S. Department of Education. Additionally, Management will work to ensure that the required contract URL is provided the U.S. Department of Education, following the agency’s requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024
During our testing of the open Perkins Loans, we selected a sample of 21 loans, 6 of the loans tested were paper MPNs electronically copied to Adobe PDF and the paper MPNs were not retained and/or stored in the fireproof container. Certified true copies of MPN’s are only allowed to be retained when the original is required to be released to enforce the loan. Questioned costs: None Context: Out of a sample of 21 open loans 6 paper signed MPNs were converted to Adobe PDF’s and the original paper MPN was not retained and/or stored in the fireproof container. Cause: The school was unaware they needed to retain the original copies. Effect: The school does not have original paper MPNs in a locked, fireproof container. Repeat Finding: No Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.038 Federal Award Identification Number and Year: N/A – Revolving Loan Portfolio Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 674.19 (e)(4)(i) requires an institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR 200.303). Condition: During our testing of the open Perkins Loans, we selected a sample of 21 loans, 6 of the loans tested were paper MPNs electronically copied to Adobe PDF and the paper MPNs were not retained and/or stored in the fireproof container. Certified true copies of MPN’s are only allowed to be retained when the original is required to be released to enforce the loan. Questioned costs: None Context: Out of a sample of 21 open loans 6 paper signed MPNs were converted to Adobe PDF’s and the original paper MPN was not retained and/or stored in the fireproof container. Cause: The school was unaware they needed to retain the original copies. Effect: The school does not have original paper MPNs in a locked, fireproof container. Repeat Finding: No Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Views of responsible officials: The University agrees with the finding. Management has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all student loan documentation is maintained per the U.S. Department of Education policies. Management will assign the respective loans back to the Department of Education as to be in compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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