University of San Francisco

Criteria: The U.S. Department of Education (ED) directs each institution to publicly post certain information related to the Emergency Financial Aid Grants to students directly on their website. Institutions must publicly post their report no later than 30 days after the publication of the notice or 30 days after the date ED first obligated the funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30). The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion for the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms: 1) the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission for each program, 2) the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under each program, 3) the total number of students who received an Emergency Financial Aid Grants to students for each program, and 4) the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under each program. Condition/Context: For the year ended May 31, 2022, the University filed four Quarterly Public Reports for Student Aid Portion. We selected all four reports for testing and noted that three (related to the quarters June 30, 2021, December 31, 2021, and March 31, 2022) were posted to the University?s website after the required posting deadline. Effect: Reporting requirements of the awards were not met timely. Cause: The University did not follow policies and procedures in a timely manner to meet the compliance requirement. Repeat finding: This is not a repeat finding. Recommendation: We recommend that management adopt a timeline based on the information set out in the guidance to ensure that reporting requirements are met.

FINDING 2019-001 ? Special Tests and Provisions ? Return of Title IV Funds: Significant Deficiency Criteria: An institution must return the total amount of unearned Title IV assistance. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student, from the amount of Title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew (34 CFR 668.22). An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR section 668.22(j)). Returns of Title IV funds are required to be deposited or transferred into the student financial aid account or electronic funds transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew (34 CFR section 668.173(b)). Condition/Context: From a population of approximately 115 students who were recipients of Title IV funding and had unofficially withdrawn during the fiscal year ended May 31, 2019, we tested 12 students for potential requirement of return of Title IV funds by comparing student records to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. From our testing, we noted two instances where the return to Title IV calculation was completed accurately and timely but funds, totaling $13,352, were not returned timely as the date of return was past the 45 days after the date of the University?s determination that the student withdrew. Effect: The University did not return certain Title IV funds timely to the U.S. Department of Education. Cause: The finding occurred due to lack of adherence to the University?s policies and procedures over return of Title IV funds and inconsistencies in performance of processing due to employee turnover in both the Registrar?s office and the Financial Aid office. Repeat finding: Although some circumstances that led to the matter differ, this finding is substantially the same as finding 2018-001 that was reported in the prior year. Recommendation: We recommend the University revise and strengthen its policies and procedures over return of Title IV funds to ensure the return of Title IV process is fully completed including verifying that funds due to the U.S. Department of Education are returned within 45 days of determining the student?s withdrawal date. Views of responsible officials and planned corrective actions: Management acknowledges and concurs with this finding. Management has implemented continual training and education of current policies and procedures and is developing additional procedures to ensure the return to Title IV process is fully completed including verifying that funds due to the U.S. Department of Education are returned timely. See Schedule of Findings and Questioned Costs for chart/table.

FINDING 2019-002 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency Criteria: The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s centralized database for students? enrollment information. It is the University?s responsibility to update this information timely and accurately when the enrollment status of a student who has received federal aid changes. The University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University?s behalf. Unless the University expects to submit its next updated enrollment report within the next 60 days, the University must notify the lender or the guaranty agency within 30 days after the date the University discovers that a student who received a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (34 CFR section 685.309(b)(2)(i)). Condition/Context: A sample of 25 federal aid recipient students were selected from system generated reports of students who graduated or withdrew during the 2018-2019 academic year. Our sample consisted of 21 students out of a population of approximately 2,300 that were identified as graduates during the year and 4 students out of a population of approximately 60 that were identified as withdrawn during the year. The enrollment information and degree award date or withdrawal date per the University?s records was compared to the information reported to the NSLDS in order to determine if status changes were reported within the required timeframes. An exception was noted with 5 graduated students out of the 25 total students that were selected for testing. The students graduating during the 2018?2019 academic year were not reported as graduated to the NSLDS within the required timeframe. The students? status for the 5 students was eventually correctly reported. Effect: The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by U.S. Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Cause: The finding occurred due to inconsistencies in performance of reporting due to employee turnover in the Registrar?s office and lack of internal controls in place to ensure student status changes are reported to NSLDS within the required timeframe. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the University develop additional procedures to monitor the accuracy of information provided to its third-party servicer after each roster file response to ensure that the enrollment status is accurate and reported timely by its third-party servicer on behalf of the University to NSLDS. The University has access to correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management acknowledges and concurs with this finding and is developing additional reporting verification of graduation submissions to ensure student status changes are reported to NSLDS within the reporting deadlines. See Schedule of Findings and Questioned Costs for chart/table.

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