EIN: 941279803
UEI: FBXYMNPM5KS6
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (37 days from today).
What is a management decision? →Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need-based federal financial aid. Criteria: 34 CFR 685.200(a) Questioned Costs: $11,187 Context: Out of 60 students tested, 6 students were not awarded aid appropriately based on need analysis. Five students received unsubsidized loans when they had remaining eligibility for subsidized loans and should have reallocated $9,579 from unsubsidized to subsidized loans. Additionally, one student was over awarded $1,608 in subsidized loans that should have been allocated to unsubsidized loans. Cause: The system configuration did not consistently update need analysis when changes to a student's institutional aid occurred. Also, there was no review in place to ensure FDL amounts awarded matched their eligibility when subsequent changes to institutional aid were made. Effect: Students not awarded need-based federal aid according to eligibility. Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need-based federal aid. We also recommend that the student information system have notifications when institutional aid changes occur and that the University implement a review of need analysis and update awarding as needed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need-based federal financial aid. Criteria: 34 CFR 685.200(a) Questioned Costs: $11,187 Context: Out of 60 students tested, 6 students were not awarded aid appropriately based on need analysis. Five students received unsubsidized loans when they had remaining eligibility for subsidized loans and should have reallocated $9,579 from unsubsidized to subsidized loans. Additionally, one student was over awarded $1,608 in subsidized loans that should have been allocated to unsubsidized loans. Cause: The system configuration did not consistently update need analysis when changes to a student's institutional aid occurred. Also, there was no review in place to ensure FDL amounts awarded matched their eligibility when subsequent changes to institutional aid were made. Effect: Students not awarded need-based federal aid according to eligibility. Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need-based federal aid. We also recommend that the student information system have notifications when institutional aid changes occur and that the University implement a review of need analysis and update awarding as needed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Planned Corrective Action: For the current award year, a new financial aid management system has been implemented to remediate prior system limitations. This system includes enhanced internal controls and calculations that align with federal requirements. The origination and disbursement processes include structured manual review, providing increased visibility into potential discrepancies and enabling timely identification and resolution of issues prior to disbursement. System-generated reports will be reviewed for implementation to identify potential over- or under-awarding of need-based federal aid, allowing for periodic review and timely corrections. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 4/29/26
Pell was not properly awarded to students based on enrollment intensity. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: 4 students out of 28 tested were not awarded Pell for summer but were eligible based on their enrollment intensity. 1 student was eligible for summer 2024 and had it reported to COD as disbursed but it was not posted to their student account. Total Pell under awarded for these students was $4,690. These were corrected during the audit. Cause: An oversight in the system configuration task marked certain student records as ineligible and the disbursements were blocked. Effect: There was an incorrect amount of Pell paid to these students. Identification as repeat finding, if applicable: Yes, 2024-004 and 2023-004 Recommendation: We recommend procedures be implemented to ensure Pell be paid in alignment with enrollment intensity including summer term. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Pell Awards Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Pell was not properly awarded to students based on enrollment intensity. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: 4 students out of 28 tested were not awarded Pell for summer but were eligible based on their enrollment intensity. 1 student was eligible for summer 2024 and had it reported to COD as disbursed but it was not posted to their student account. Total Pell under awarded for these students was $4,690. These were corrected during the audit. Cause: An oversight in the system configuration task marked certain student records as ineligible and the disbursements were blocked. Effect: There was an incorrect amount of Pell paid to these students. Identification as repeat finding, if applicable: Yes, 2024-004 and 2023-004 Recommendation: We recommend procedures be implemented to ensure Pell be paid in alignment with enrollment intensity including summer term. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Pell Awards Planned Corrective Action: For the current award year, a new financial aid management system has been implemented to remediate prior system limitations. The new system includes automated calculations aligned with federal requirements, ensuring Pell Grant awards are based on students’ enrollment in eligible coursework. The origination and disbursement processes now incorporate structured manual oversight to further ensure accuracy and compliance. Review procedures will be implemented to ensure Pell awards and disbursements align with enrollment status. This will include using system-generated reports to identify and correct discrepancies before disbursement. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 4/29/26
2024-004, 2023-004
The dates that Pell and Federal Direct Loans (FDL) were disbursed to student accounts did not always agree to the disbursement dates as reported in COD. Criteria: 34 CFR 668.164(a) Questioned Costs: $0 Context: Out of 134 transactions tested, including both Pell and FDL disbursements, 10 transactions on COD did not reflect the actual disbursement date per the student account statement. 5 of 38 students tested had COD loan disbursement date errors ranging from 8-22 days. 5 of the 28 Pell students tested had COD disbursement date errors ranging from 8-82 days. The majority of errors were in the Fall term. There were no errors in the amounts reported, just the date of disbursement. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the student accounts and the errors were not caught during the reconciliations of University records to COD. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University implement procedures to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and that disbursement dates be reviewed as part of the monthly reconciliation process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Common Origination and Disbursement (COD) Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants and 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The dates that Pell and Federal Direct Loans (FDL) were disbursed to student accounts did not always agree to the disbursement dates as reported in COD. Criteria: 34 CFR 668.164(a) Questioned Costs: $0 Context: Out of 134 transactions tested, including both Pell and FDL disbursements, 10 transactions on COD did not reflect the actual disbursement date per the student account statement. 5 of 38 students tested had COD loan disbursement date errors ranging from 8-22 days. 5 of the 28 Pell students tested had COD disbursement date errors ranging from 8-82 days. The majority of errors were in the Fall term. There were no errors in the amounts reported, just the date of disbursement. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the student accounts and the errors were not caught during the reconciliations of University records to COD. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University implement procedures to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and that disbursement dates be reviewed as part of the monthly reconciliation process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: For the current award year, a new financial aid management system has been implemented to remediate prior system limitations. The origination and disbursement processes now incorporate structured manual oversight to further ensure accuracy and compliance. In addition, monthly reconciliation processes will be strengthened to include a review of disbursement dates reported to COD compared to institutional records. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 4/29/26
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 9 students, 1 student who withdrew during the audit period tested had funds of $3,125 returned 6 days late. Cause: There were delays in processing R2T4’s corrections as a result of issues with Regent sending the updates to COD. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2024-001 and 2023-002 Recommendation: We recommend that financial aid office staff work with the registrar to put procedures in place for timely notification when students stop attending, and that financial aid staff process the R2T4’s timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants and 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 9 students, 1 student who withdrew during the audit period tested had funds of $3,125 returned 6 days late. Cause: There were delays in processing R2T4’s corrections as a result of issues with Regent sending the updates to COD. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2024-001 and 2023-002 Recommendation: We recommend that financial aid office staff work with the registrar to put procedures in place for timely notification when students stop attending, and that financial aid staff process the R2T4’s timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: For the current award year, a new financial aid management system has been implemented to remediate prior system limitations. In addition, enhanced internal controls have been implemented, including a more stringent tracking and monitoring process, to ensure timely processing and return of Title IV funds in compliance with federal requirements. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 4/29/2026
2024-001, 2023-002
FAC accepted this audit on January 10, 2025 — management decision was due July 10, 2025.
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately and did not update NSLDS correctly. Criteria: 34 CFR 668.22, 34 CFR 685.309(b) Questioned Costs: $3,523 Context: Out of 23 students, 3 students had inaccurate returns, resulting in underawards of Pell of $3,146 and overawards of loans of $3,523. Out of the same 23 students, 4 students who withdrew during the audit period tested had a total of approximately $11,759 funds returned late ranging from 7 to 73 days. Additionally 2 students have funds that still need to be returned. Additionally, two students who withdrew were not updated correctly in NSLDS. Cause: There were staffing challenges during the year as well as delays in processing R2T4’s corrections even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education. The date of determination was used for the enrollment reporting updates instead of the date of withdrawal. Effect: Returns of Title IV funds were not performed timely or accurately. Identification as repeat finding, if applicable: Yes, 2023-002 and 2022-001 Recommendation: We recommend that additional training be completed on R2T4 processing and related updates to NSLDS for withdrawals. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely and Inaccurate Returns of Title IV Funds (R2T4) and National Student Loan Data System Updates (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately and did not update NSLDS correctly. Criteria: 34 CFR 668.22, 34 CFR 685.309(b) Questioned Costs: $3,523 Context: Out of 23 students, 3 students had inaccurate returns, resulting in underawards of Pell of $3,146 and overawards of loans of $3,523. Out of the same 23 students, 4 students who withdrew during the audit period tested had a total of approximately $11,759 funds returned late ranging from 7 to 73 days. Additionally 2 students have funds that still need to be returned. Additionally, two students who withdrew were not updated correctly in NSLDS. Cause: There were staffing challenges during the year as well as delays in processing R2T4’s corrections even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education. The date of determination was used for the enrollment reporting updates instead of the date of withdrawal. Effect: Returns of Title IV funds were not performed timely or accurately. Identification as repeat finding, if applicable: Yes, 2023-002 and 2022-001 Recommendation: We recommend that additional training be completed on R2T4 processing and related updates to NSLDS for withdrawals. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely and Inaccurate Returns of Title IV Funds (R2T4) and National Student Loan Data System Updates (NSLDS) Planned Corrective Action: We will provide additional training to financial aid staff on Return to Title IV (R2T4) processing from a third party servicer with expertise in processing with our current financial aid management system. We will also collaborate with the Registrar’s Office to implement a system that ensures timely notification of student withdrawals, enabling the financial aid office to process R2T4 returns within the required timeframe. We will establish more robust internal controls to verify that withdrawals are correctly updated in NSLDS, and review staffing needs to ensure adequate resources for processing Title IV aid returns efficiently. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025
2023-002
As required under 34 CFR 668.56, for students who are flagged for verification, the University is required to obtain underlying tax and other information to verify that amounts are properly reported on the ISIR and correct the ISIR if there are discrepancies. The University did not complete verification accurately for three students. Criteria: 34 CFR 668.56 Questioned Costs: $4,300 Context: Out of 9 tested for verification, 3 students had an incorrect number in household and number in family reported that caused a change in expected family contribution. Two of those students resulted in a total of $4,300 over awarded in the student’s Pell grants. One additional student was not recalculated as the federal system for updates was closed. Cause: The verification corrections did not process fully within Regent. There was not proper review of student’s files to ensure the correct information was updated on the ISIR used for packaging the student’s financial aid. Effect: Need based aid and specifically Pell grants are impacted directly by the results of verification Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University periodically review verification completed for students with need-based aid for accuracy and ensure any corrections are properly reflected in the student information system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Verification Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: As required under 34 CFR 668.56, for students who are flagged for verification, the University is required to obtain underlying tax and other information to verify that amounts are properly reported on the ISIR and correct the ISIR if there are discrepancies. The University did not complete verification accurately for three students. Criteria: 34 CFR 668.56 Questioned Costs: $4,300 Context: Out of 9 tested for verification, 3 students had an incorrect number in household and number in family reported that caused a change in expected family contribution. Two of those students resulted in a total of $4,300 over awarded in the student’s Pell grants. One additional student was not recalculated as the federal system for updates was closed. Cause: The verification corrections did not process fully within Regent. There was not proper review of student’s files to ensure the correct information was updated on the ISIR used for packaging the student’s financial aid. Effect: Need based aid and specifically Pell grants are impacted directly by the results of verification Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University periodically review verification completed for students with need-based aid for accuracy and ensure any corrections are properly reflected in the student information system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification Planned Corrective Action: We have contracted a third party servicer to complete and review verification for the current academic year to ensure accuracy and completion. We will establish an a process for periodic audits will be conducted to verify the accuracy of all completed verifications for students flagged. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025
The University did not accurately report certain items relating to Pell Grant Reporting on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The University did not properly report Pell Grant information on the most recent FISAP. Cause: This was an oversight by management. When initial Pell figures were reported on the FISAP, subsequent adjustments were made based on year-end reconciliations and the University did not reflect the corrections in the FISAP report. Effect: The FISAP Pell grant expenditures was understated by approximately 12%. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University have an independent individual review the FISAP prior to submission for accuracy. We also recommend the University work with the Department of Education to correct errors in the Pell reporting portion of the FISAP. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴FISAP Reporting DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not accurately report certain items relating to Pell Grant Reporting on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The University did not properly report Pell Grant information on the most recent FISAP. Cause: This was an oversight by management. When initial Pell figures were reported on the FISAP, subsequent adjustments were made based on year-end reconciliations and the University did not reflect the corrections in the FISAP report. Effect: The FISAP Pell grant expenditures was understated by approximately 12%. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University have an independent individual review the FISAP prior to submission for accuracy. We also recommend the University work with the Department of Education to correct errors in the Pell reporting portion of the FISAP. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
FISAP Reporting Planned Corrective Action: In partnership with our third party servicer, we have contracted there independent review of the 25-26 FISAP report prior to submission to ensure all figures are accurate. We will coordinate with the Department of Education to correct errors related to Pell reporting on the 24-25 FISAP. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025
1 student out of 60 was not properly awarded Pell based on the classes they began attendance in. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: One student inadvertently had Pell recalculated automatically after the beginning of the second session within the term, and because the student had withdrawn from two classes, the Pell was adjusted as if attendance had never begun resulting in an under award of $536. Cause: This was an oversight in the system configuration. Effect: Pell was under awarded for classes where the student began attendance and subsequently withdrew. Identification as repeat finding, if applicable: Yes 2023-004 Recommendation: We recommend the system configuration allow a check box that indicates the student began attendance in a Pell eligible class. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Pell Awards DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: 1 student out of 60 was not properly awarded Pell based on the classes they began attendance in. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: One student inadvertently had Pell recalculated automatically after the beginning of the second session within the term, and because the student had withdrawn from two classes, the Pell was adjusted as if attendance had never begun resulting in an under award of $536. Cause: This was an oversight in the system configuration. Effect: Pell was under awarded for classes where the student began attendance and subsequently withdrew. Identification as repeat finding, if applicable: Yes 2023-004 Recommendation: We recommend the system configuration allow a check box that indicates the student began attendance in a Pell eligible class. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Pell Awards Planned Corrective Action: The system configuration has been reviewed and updated to ensure students Pell eligibility is are accurately awarded based on attendance. A review process will be implemented to manually verify Pell awards for students who withdraw from classes to ensure that adjustments are made appropriately Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025
2023-004
FAC accepted this audit on February 28, 2024 — management decision was due August 28, 2024.
The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Common Origination and Disbursement (COD) Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The dates when Federal Direct Loans (FDL) and Pell were disbursed to student's account did not always agree to the disbursement dates as reported in COD. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Out of 259 subsidized, unsubsidized, Plus loans, and Pell disbursement records tested, 25 had COD loan and Pell disbursement date errors. The errors were primarily a spring 2023 disbursement batch which reported Pell and FDL disbursements to COD as 2/21/2023 but were actually posted to the students’ accounts on 3/24/2023. There were no errors in the amounts reported, just the date of disbursement and the funds were not drawn down from G5 until 3/28/2023 so no cash management violation noted. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students' accounts. Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students, 3 students who withdrew during the audit period tested had a total of $7,790 funds returned late ranging from 35 to 83 days. For 1 of these students, the University originally had incorrectly returned all of the student’s Pell but no FDL so the net funds returned late were $594. 2 of these students had a total of $983 more in FDL returned than the required. Cause: Staffing challenges. Delays in processing R2T4’s even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2022-001 Recommendation: We recommend that additional training be completed on R2T4 processing. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely Returns of Title IV Funds (R2T4)Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students, 3 students who withdrew during the audit period tested had a total of $7,790 funds returned late ranging from 35 to 83 days. For 1 of these students, the University originally had incorrectly returned all of the student’s Pell but no FDL so the net funds returned late were $594. 2 of these students had a total of $983 more in FDL returned than the required. Cause: Staffing challenges. Delays in processing R2T4’s even though the calculations were completed timely. While the calculations were completed correctly, the actual amounts returned included the funds that both the school and student were responsible for returning to the Department of Education. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2022-001 Recommendation: We recommend that additional training be completed on R2T4 processing. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending and that financial aid process the R2T4’s timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete R2T4s. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
2022-001
The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not: - implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA. Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated 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 formalize and document processes to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not: - implemented multi-factor authentication on one vendor system containing personally identifiable information (PII) - implemented sufficient vendor management policies and reviews - provided a written, annual report to the board We noted the University has been evaluating vendors, and the criteria for evaluating vendors is being revised to incorporate the updated regulations of GLBA. Additionally, while information related to the information security program has been shared with the board, a more robust written report will be implemented. We commend the University for the work completed related to GLBA. Cause: The University has not formalized all documentation of processes and upcoming revised vendor management processes to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated 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 formalize and document processes to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: For the vendor that does not have multi factor authentication (National Clearinghouse), we are implementing their new platform, Myhub, to ensure compliance. We anticipate completion by 3/1/24. Additionally, we engaged a firm that will serve as a virtual Chief Information Security Officer to manage the continuing GLBA updates for regulatory compliance. Person Responsible for Corrective Action Plan: Judy Rentz, V.P of Operations/Chief Operating Officer Anticipated Date of Completion: March 1, 2024
Students were not always properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: Out of 33 students tested, 1 student was eligible for Pell of $1,724 in the spring term but was not awarded due to an error in the auto packaging calculation in the system. This was corrected during the audit. 1 student had not used their full annual Pell eligibility and was under awarded Pell by $618 for the summer term. Cause: Incorrect system setup in Regent Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend a process be used to review system setups to adjust Pell to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Pell Awards DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not always properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: Out of 33 students tested, 1 student was eligible for Pell of $1,724 in the spring term but was not awarded due to an error in the auto packaging calculation in the system. This was corrected during the audit. 1 student had not used their full annual Pell eligibility and was under awarded Pell by $618 for the summer term. Cause: Incorrect system setup in Regent Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend a process be used to review system setups to adjust Pell to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Pell Awards Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of verifying students’ enrollment status. Person Responsible for Corrective Action Plan: Cathy Morgan Anticipated Date of Completion: March 1, 2024
FAC accepted this audit on February 14, 2023 — management decision was due August 14, 2023.
When students withdrew either officially or unofficially, the University did not always complete R2T4 calculations accurately and return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $10,417 Context: Out of 29 withdrawn students tested for timely and accurate R2T4?s, 13 had either late returns, inaccurate returns or both. 6 students had a total of $12,154 returned late ranging from 9 to 154 days, with $811 included in questioned costs for a return made as part of audit process. 2 students had $22,715 returned late ranging from 21 to 151 days, which includes $9,606 in questioned costs for miscalculations identified in the audit resulting in additional funds required to be returned. 3 students had $5,490 returned late ranging from 6 to 28 days late, however 2 had correct calculations but $1,009 more was returned than required and the other had an incorrect calculation resulting in $3,516 more returned than required. 1 student who withdrew from a modular program met an exemption but the University returned $1,652 that the student was eligible to keep. 1 other student had a $615 post withdraw disbursement that was made 90 days late. Cause: Significant staff turnover in financial aid office as well as a system conversion. There is also a lack of understanding regarding the new modular withdraw regulations. Effect: The correct amount of Title IV funds not returned timely as required. Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that additional training be completed on R2T4 calculations and the new modular withdraw regulations. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Late Returns of Title IV Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always complete R2T4 calculations accurately and return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $10,417 Context: Out of 29 withdrawn students tested for timely and accurate R2T4?s, 13 had either late returns, inaccurate returns or both. 6 students had a total of $12,154 returned late ranging from 9 to 154 days, with $811 included in questioned costs for a return made as part of audit process. 2 students had $22,715 returned late ranging from 21 to 151 days, which includes $9,606 in questioned costs for miscalculations identified in the audit resulting in additional funds required to be returned. 3 students had $5,490 returned late ranging from 6 to 28 days late, however 2 had correct calculations but $1,009 more was returned than required and the other had an incorrect calculation resulting in $3,516 more returned than required. 1 student who withdrew from a modular program met an exemption but the University returned $1,652 that the student was eligible to keep. 1 other student had a $615 post withdraw disbursement that was made 90 days late. Cause: Significant staff turnover in financial aid office as well as a system conversion. There is also a lack of understanding regarding the new modular withdraw regulations. Effect: The correct amount of Title IV funds not returned timely as required. Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that additional training be completed on R2T4 calculations and the new modular withdraw regulations. We also recommend that financial aid office work with the registrar to put procedures in place for timely notification when students stop attending. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV Calculations Planned Corrective Action: We worked with staff to better understand whether the delayed and incorrect R2T4 calculations were a result of knowledge or process deficiencies. After speaking with staff, we determined that both areas are an issue. To address these deficiencies, we are employing the following measures: 1) We have engaged a consultant for group training on R2T4?s. This consultant will also help with process review, to help us understand any areas of weakness. 2) We will have staff re-review the FSA training modules on R2T4?s. 3) We have upgraded to a new financial aid management system. This system allows for automated/semi-automated R2T4 processing, which will help ensure that R2T4?s are completed accurately and in a timely manner. Person Responsible for Corrective Action Plan: Alison Hayes, Assistant Director of Financial Aid Anticipated Date of Completion: N/A- ongoing training and process review.
The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for the American Rescue Plan (ARP) student portion expended. Criteria: 86 FR 262132, CFR 200.329. For each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that while the University had appropriately disclosed the required CARES Act and CRRSAA Act reporting and ARP institutional reporting for HEERF institutional funds, the ARP student emergency grant disbursements were not disclosed on their website. The University corrected and amounts were posted to the website before the audit was finalized. Cause: There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: n/a Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund Reporting Other Matter DEPARTMENT OF EDUCATION ALN #: 84.425E Education Stabilization Fund Federal Award Identification #: P425E202939 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for the American Rescue Plan (ARP) student portion expended. Criteria: 86 FR 262132, CFR 200.329. For each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that while the University had appropriately disclosed the required CARES Act and CRRSAA Act reporting and ARP institutional reporting for HEERF institutional funds, the ARP student emergency grant disbursements were not disclosed on their website. The University corrected and amounts were posted to the website before the audit was finalized. Cause: There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: n/a Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Planned Corrective Action: We uploaded the quarterly report for the use of the ARP student portion on the institution?s website late in August 2022. Now that both the student portion and the institution portion are required to be reported on one quarterly report provided by the Department, we will make sure the report is filed on time and concurrently post it on the institution?s website. Person Responsible for Corrective Action Plan: Diane Ahn, VP for Finance and CFO Anticipated Date of Completion: Completed
FAC accepted this audit on January 4, 2022 — management decision was due July 4, 2022.
The dates when Federal Direct Loans (FDL) were disbursed to students? account did not always agree to the disbursement dates as reported in COD. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Out of 167 subsidized, unsubsidized and Plus loans disbursement records tested, 13 had COD loan disbursement date errors ranging from 18-102 days. The majority of the errors were in the fall 2020 term. There were no errors in the amounts reported, just the date of disbursement. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that FDL were disbursed to the students? accounts. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-001 Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2020-21 Financial Aid Year Condition: The dates when Federal Direct Loans (FDL) were disbursed to students? account did not always agree to the disbursement dates as reported in COD. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Out of 167 subsidized, unsubsidized and Plus loans disbursement records tested, 13 had COD loan disbursement date errors ranging from 18-102 days. The majority of the errors were in the fall 2020 term. There were no errors in the amounts reported, just the date of disbursement. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that FDL were disbursed to the students? accounts. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-001 Common Origination and Disbursement (COD) Reporting Planned Corrective Action: We contacted the COD School Relations Center to determine a solution for reporting the correct disbursement date in COD for late disbursements made more than 30 days after the end of the term. They indicated that we may receive a warning when we enter a disbursement date more than 30 days after the end of the term, but it should not prevent us from pushing the disbursement through with the correct date. To prevent this issue in the future, we will 1) contact COD immediately if we continue to experience the system issue pre venting us from reporting the correct disbursement date in COD; 2) decrease the number of late disbursements made more than 30 days after the end of the term by engaging in greater student outreach earlier in the term. Person Responsible for Corrective Action Plan: Alison Hayes, Assistant Director of Financial Aid. Anticipated Date of Completion: N/A- procedural change.
FAC accepted this audit on November 6, 2019 — management decision was due May 6, 2020.
The University did not always report enrollment status to NSLDS accurately and timely for student who withdrew. Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: 2 of 31 students tested did not have the effective date of their withdrawal correctly updated in NSLDS. These students were in the process of being corrected. Effect: Inaccurate or late reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. These two students received an additional deferment period of a couple of months. Cause: The incorrect date was being pulled into the report that was being submitted to the clearinghouse which in turn was reporting to NSLDS. Identification as repeat finding, if applicable: Yes, 2018-001. Recommendation: We recommend the University use a field in the student information system that can be queried for the NSDLS data in order to properly report the effective date for withdrawals. Views of Responsible Officials: Management is in agreement with the recommendation and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 Reporting Enrollment Status to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2018-2019 Award Year Condition: The University did not always report enrollment status to NSLDS accurately and timely for student who withdrew. Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: 2 of 31 students tested did not have the effective date of their withdrawal correctly updated in NSLDS. These students were in the process of being corrected. Effect: Inaccurate or late reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. These two students received an additional deferment period of a couple of months. Cause: The incorrect date was being pulled into the report that was being submitted to the clearinghouse which in turn was reporting to NSLDS. Identification as repeat finding, if applicable: Yes, 2018-001. Recommendation: We recommend the University use a field in the student information system that can be queried for the NSDLS data in order to properly report the effective date for withdrawals. Views of Responsible Officials: Management is in agreement with the recommendation and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2019-001 Reporting Enrollment Status to NSLDS Planned Corrective Action: The return calculations are now being performed in the student information system. This requires a last date of attendance field, which can be queried to report the correct effective date for NSLDS. Financial Aid will work with institutional research on a monthly basis to confirm the proper LDA and enrollment status before a flat file is sent to NSC. Furthermore, additional manual review will be performed on withdrawals. Person Responsible for Corrective Action Plan: John Swan, Director of Financial Aid Anticipated Date of Completion: September 2019
2018-001
FAC accepted this audit on October 2, 2018 — management decision was due April 2, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on November 21, 2016 — management decision was due May 21, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-002
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.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.