EIN: 951664100
UEI: N34CXJCDNDU1
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 16, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 16, 2026 (42 days ago).
What is a management decision? →FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (SEE FINDING 2025-001 FOR INCLUDED TABLE) Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 20 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Cause – The review procedures in place do not sufficiently address situations involving the Degree Verify transmission failures. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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. Repeat finding – This is not a repeat finding. Recommendation – We recommend the University establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the University’s behalf, for completeness and accuracy. We also recommend the University establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – Management agrees and has created a corrective action plan.
Show full finding ▾Hide full finding ▴FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (SEE FINDING 2025-001 FOR INCLUDED TABLE) Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student 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; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – A sample of 20 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Cause – The review procedures in place do not sufficiently address situations involving the Degree Verify transmission failures. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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. Repeat finding – This is not a repeat finding. Recommendation – We recommend the University establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the University’s behalf, for completeness and accuracy. We also recommend the University establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – Management agrees and has created a corrective action plan.
Claremont Graduate University Corrective Action Plan For the Fiscal Year Ended June 30, 2025 U.S. Department of Education FINDING 2025-001 – Special Tests and Provisions-Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Condition – During the audit fieldwork, a sample of 20 federal aid recipient students were selected by auditors from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Explanation of Deficiency On June 20, 2025, the Degree Verify transmission to the National Student Clearinghouse (NSC) failed. Additionally, an error was identified that caused all international student records to be rejected. In order to correct the omission of international students, the monthly transmission was temporarily stopped until the issue could be resolved. This process took longer than anticipated. While degree records were being manually updated in NSC, staff were not aware that the enrollment records also needed to be separately updated. The Degree Verify file had been configured with a flag that should have automatically updated enrollment records upon submission, but this was not recognized at the time. As a result, a sample of student files reviewed contained reporting errors related to incorrect enrollment statuses or reporting delays. These issues would have been avoided if regularly scheduled reports had been submitted to NSC without interruption. Corrective Action Plan To address these deficiencies and prevent recurrence, the following corrective measures have been implemented: 1. Resumption of Scheduled Transmissions – The Office of Information Technology has corrected the Degree Verify file rejection issue. Monthly transmissions of Degree Verify reports will resume beginning September 20, 2025. 2. Enhanced Enrollment Reporting Schedule – Enrollment reporting has been rescheduled to occur every three weeks throughout each term, ensuring that enrollment status changes are reported to NSC and NSLDS within required timeframes. 3. Manual Record Reconciliation – A comprehensive review of late degree conferrals has been completed. All enrollment records have been manually updated in NSC to align with the corresponding degree records. 4. Staff Training and Awareness – The Registrar’s Office staff have been trained on the functional differences between degree reporting and enrollment reporting. Emphasis was placed on the need to verify that enrollment records are updated when degree records are manually corrected. 5. Monitoring and Quality Control – A reconciliation process has been established between the Registrar’s Office and OIT to confirm the successful transmission and acceptance of NSC files. Reports of any rejected records will be reviewed within five business days and promptly corrected. Contact Person Responsible: Vannessa Alvarado, Registrar 909-621-8285 Anticipated/Projected Completion Date: Manual corrections completed on September 3, 2025. Automated processes to projected September 20, 2025.
FAC accepted this audit on November 30, 2022 — management decision was due May 30, 2023.
FINDING 2022-001 - Reporting: Significant Deficiency over Internal Controls over Compliance: "See Schedule of Findings and Questioned Costs for chart/table". Criteria: According to an electronic announcement (EA) by U.S. Department of Higher Education (ED) on May 6, 2020, ED required institutions that received a Higher Education Emergency Relief Fund (HEERF) 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the EA with 85 FR 53802, which decreased the frequency of subsequent reporting from every 45 days to every calendar quarter. Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely posting of special reports to their website. Condition/Context: The University did not publicly post a special report on a timely basis. The University is required to prepare and publicly post a special report (Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting) with certain information describing the use of funds distributed from the HEERF on their website no later than 30 days after receiving the award. The University was required to publicly post the initial report to its website by January 10, 2022, however, the University first publicly posted the initial report to its website on January 14, 2022. Cause: In discussing these conditions with University management, the delay in publicly posting the special report to the University?s website was due to resource constraints as the University?s information systems personnel were implementing technology to effectively transition to distance learning and remote work in light of the COVID-19 pandemic and related shelter-in-place orders. Effect: Failure to publicly post special reports to the University?s website on a timely basis does not allow the public to access timely information on how the University used the funds received from the HEERF. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University implement procedures to ensure special reports are posted to the University?s website in a timely manner. Views of responsible officials: We agree with the auditor?s comments. These were unprecedented times, and this type of failure is inconsistent with past practice. Reporting requirements are tracked internally via the BlueSky deliverable system. Publishing access to the reporting website has been granted to the Restricted Accounting Supervisor to avoid additional publishing delays.
Show full finding ▾Hide full finding ▴FINDING 2022-001 - Reporting: Significant Deficiency over Internal Controls over Compliance: "See Schedule of Findings and Questioned Costs for chart/table". Criteria: According to an electronic announcement (EA) by U.S. Department of Higher Education (ED) on May 6, 2020, ED required institutions that received a Higher Education Emergency Relief Fund (HEERF) 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the EA with 85 FR 53802, which decreased the frequency of subsequent reporting from every 45 days to every calendar quarter. Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely posting of special reports to their website. Condition/Context: The University did not publicly post a special report on a timely basis. The University is required to prepare and publicly post a special report (Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting) with certain information describing the use of funds distributed from the HEERF on their website no later than 30 days after receiving the award. The University was required to publicly post the initial report to its website by January 10, 2022, however, the University first publicly posted the initial report to its website on January 14, 2022. Cause: In discussing these conditions with University management, the delay in publicly posting the special report to the University?s website was due to resource constraints as the University?s information systems personnel were implementing technology to effectively transition to distance learning and remote work in light of the COVID-19 pandemic and related shelter-in-place orders. Effect: Failure to publicly post special reports to the University?s website on a timely basis does not allow the public to access timely information on how the University used the funds received from the HEERF. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University implement procedures to ensure special reports are posted to the University?s website in a timely manner. Views of responsible officials: We agree with the auditor?s comments. These were unprecedented times, and this type of failure is inconsistent with past practice. Reporting requirements are tracked internally via the BlueSky deliverable system. Publishing access to the reporting website has been granted to the Restricted Accounting Supervisor to avoid additional publishing delays.
2022-001 Reporting: Significant Deficiency over Internal Controls over Contact person responsible for corrective action: Juan Hernandez, AVP for Finance Completion date: September 30, 2022 Summary of new and revised controls used to ensure timely posting of the special reports: Part 1: Starting with the quarter ended 9/30/2022 the AVP for Finance will send calendar reminders to Pre-Award, Post Award, Financial Aid, Finance, and other parties involved to set a reminder of submission deadlines for each quarterly report and set an internal deadline prior to such due date. Due dates are specified by OMB Control Number 1840-0849, the reporting deadline for quarterly reports is 10 days after each reporting period. Additionally, the AVP for Finance will now be the responsible party to coordinate and submit the report to the DOE and to initiate the upload to the university website with the help of all the aforementioned parties. Part 2: In addition to the calendar invitation in part 1 above, the AVP will be responsible for submitting the report to the DOE and emailing all parties involved confirming that the report was submitted to the DOE. This email will confirm that the report is final and will indicate to designated uploader (currently financial aid department) to make the information public by uploading it to the CGU CARES website. Once this is uploaded the uploader will send a follow up email to all parties involved to confirm that the upload to the website has occurred.
FAC accepted this audit on November 20, 2021 — management decision was due May 20, 2022.
FINDING 2021-001 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency in Internal Controls and Instance of Non-Compliance 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). For a student that does not return from an approved leave of absence (LOA), the withdrawal date for purposes of the return of Title IV calculation is the date the student began the LOA (34 CFR668.22(c) and (l)). Returns of Title IV (R2T4) funds are required to be deposited or transferred into the student account or electronic funds transfers initiated to the 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: In testing returns of Title IV funds, we selected a random sample of 4 students out of a population of 17 who had received student financial assistance and had withdrawn or taken a LOA from the University during the 2020-2021 fiscal year as identified by internal records. We noted one student qualified for an approved LOA on 9/29/2020 for the Fall 2020 semester but did not re-enroll for the Spring 2021 semester which began on 1/19/2021. This event triggers the R2T4 calculation Performance and compliance steps. The University performed the calculation and returned funds on 8/5/2021, outside of the required time frame. Cause: There was a lapse in internal controls surrounding monitoring the enrollment of students on a LOA. Effect: The financial aid office did not process a timely return of funds for one student. Repeat Finding: This is not a repeat finding. Recommendation: We recommend both the enrollment services and the financial aid departments implement a policy to monitor the enrollment status of students on LOAs. Views of responsible officials: Management agrees there was a lapse in controls surrounding monitoring the enrollment of students on a LOA. New and revised controls will be implemented to ensure students on a LOA either re-enroll at the end of their LOA or become classified as withdrawals. These controls include performing weekly reviews to identify students who have dropped to zero units and establishing 30-day, 60-day, 90-day, and 120-day reviews for all LOA requests. Additionally, all students requesting a LOA will be reviewed by the Director of Financial Aid and counseled as appropriate.
Show full finding ▾Hide full finding ▴FINDING 2021-001 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency in Internal Controls and Instance of Non-Compliance 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). For a student that does not return from an approved leave of absence (LOA), the withdrawal date for purposes of the return of Title IV calculation is the date the student began the LOA (34 CFR668.22(c) and (l)). Returns of Title IV (R2T4) funds are required to be deposited or transferred into the student account or electronic funds transfers initiated to the 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: In testing returns of Title IV funds, we selected a random sample of 4 students out of a population of 17 who had received student financial assistance and had withdrawn or taken a LOA from the University during the 2020-2021 fiscal year as identified by internal records. We noted one student qualified for an approved LOA on 9/29/2020 for the Fall 2020 semester but did not re-enroll for the Spring 2021 semester which began on 1/19/2021. This event triggers the R2T4 calculation Performance and compliance steps. The University performed the calculation and returned funds on 8/5/2021, outside of the required time frame. Cause: There was a lapse in internal controls surrounding monitoring the enrollment of students on a LOA. Effect: The financial aid office did not process a timely return of funds for one student. Repeat Finding: This is not a repeat finding. Recommendation: We recommend both the enrollment services and the financial aid departments implement a policy to monitor the enrollment status of students on LOAs. Views of responsible officials: Management agrees there was a lapse in controls surrounding monitoring the enrollment of students on a LOA. New and revised controls will be implemented to ensure students on a LOA either re-enroll at the end of their LOA or become classified as withdrawals. These controls include performing weekly reviews to identify students who have dropped to zero units and establishing 30-day, 60-day, 90-day, and 120-day reviews for all LOA requests. Additionally, all students requesting a LOA will be reviewed by the Director of Financial Aid and counseled as appropriate.
Management?s Corrective Action Plan 2021-001 ? Return of Title IV Funds ? Significant Deficiency in Internal Controls over Compliance Contact person responsible for corrective action: Kristal Gama Anticipated completion date: September 1, 2021 Summary of new and revised controls used to ensure timely processing of enrollment changes and process R2T4 calculations accurately and efficiently: ? Perform weekly review to identify student who have dropped to zero units. ? Set 30-day, 60-day, 90-day & 120-day reviews for all Leaves of Absence requests ? All students requesting a Leave of Absence will be reviewed by the Director of Financial Aid and counseled as appropriate. Institutional Action Plan: Student Leave Of Absences (LOA) and Withdrawals are monitored to determine if/when an R2T4 is required, based upon the circumstances of the enrollment change. Monitoring for students on an Leave Of Absence will include benchmarks and established checkpoints to plan for the student?s return from an LOA. Students on an LOA that do not enroll/return from an LOA by the 120th day from the date on which the LOA began will be subject to an R2T4, using the LOA begin date as the withdrawal date for the R2T4 calculation. Communication Overview: Students will be notified when an R2T4 is processed. Students beginning an LOA will notified of their option to cancel/return their Title IV Aid, the expectation to return from an LOA, and when and R2T4 will take place if they do not return from an LOA. While on an LOA, students will receive periodic notifications indicating the expectation to return from LOA and when an R2T4 will be performed. Updates have been made to our R2T4 definition, policy, and procedures to reflect the following: A student begins earning Title IV funds on the first day of attendance, even if the student withdraws before the semester?s add/drop deadline, CGU must perform an R2T4 calculation using the number of days the student attended class. A Leave of Absence (LOA) for R2T4 purposes is a temporary interruption in a student?s program of study. LOA refers to the specific time period during a program when a student is not in attendance. An LOA is not required if a student is not in attendance only for an institutionally scheduled break. However, a scheduled break may occur during an LOA. An LOA must meet certain conditions to be counted as a temporary interruption in a student?s education instead of being counted as a withdrawal requiring CGU to perform an R2T4 calculation. If an LOA does not meet the conditions for an approved LOA (see below), the student is considered to have ceased attendance and to have withdrawn from CGU, and CGU is required to perform an R2T4 calculation. For an LOA to qualify as R2T4-approved: ? CGU must have a formal written policy regarding leaves of absence requiring that all requests for leaves of absence be submitted in writing and include the reason for the student?s request. ? The student must request, and CGU must approve, the LOA in accord with CGU?s policy. ? There must be a reasonable expectation that the student will return from the LOA. This condition is specified to make clear that CGU may not grant a student an LOA merely to delay the return of unearned Title IV funds. ? CGU may not assess the student any additional institutional charges, the student?s need may not increase, and, therefore, the student is not eligible for any additional Title IV aid. ? The LOA, together with any additional leaves of absence, must not exceed a total of 180 days in any 12-month period. ? If the student has a Title IV loan, CGU must explain to them, prior to granting the LOA, the effects that his failure to return from an LOA may have on the loan repayment terms, including the expiration of the grace period.
FAC accepted this audit on November 15, 2020 — management decision was due May 15, 2021.
FINDING 2020-001 ? Special Tests and Provisions ? Enrollment Reporting and Return of Title IV Funds ? Significant Deficiency in Internal Controls and Instance of Non-Compliance (See Schedule of Findings and Questioned Costs for table) Criteria: The National Student Loan Data System (?NSLDS?) is the Department of Education?s (?ED?s?) centralized database for students? enrollment information. In accordance with the NSLDS Enrollment Reporting Guidelines (Guide), published by ED, the timeliness of reporting is important to ensure that students receive their entitled deferment benefits and it provides Congress with necessary enrollment and graduation rates of grant and loan recipients. It is the Institute?s responsibility to update this information. The Guide also emphasizes that even if an Institute uses an enrollment reporting servicer, the Institute still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for reporting any changes in student enrollment status in a timely manner. The Institute determines how often it receives the Enrollment Reporting roster file with the default set at every 2 months. Schools must complete and return within 30 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). Unless the Institute expects to complete its next roster within 60 days, the Institute must notify the lender or the guaranty agency within 30 days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). Condition/Context: In testing individual student status changes, we selected a random sample of 18 students out of a population of 128 who had received student financial assistance and had withdrawn or graduated from the Institute during the 2019-2020 fiscal year as identified by internal records. We compared the enrollment information and withdrawal or graduation date per the Institute?s records to the information reported to NSLDS. We noted 2 selections were reported outside of required time frames. Student A withdrew on 4/10/2020 and the status change was reported to NSLDS on 7/13/2020, which is 93 days after the withdrawal date. The funds were returned outside of the required time frame for returning funds. Student B withdrew on 9/16/2019 and funds were returned timely on 9/20/2019. However, Student B?s status change was reported to NSLDS on 12/13/2019, which is 88 days after the withdrawal date. Cause: The delays were by a lapse in internal controls within the enrollment services department. Effect: Status changes for Student A and Student B were not reported to NSLDS timely. As a result, the financial aid office also did not process a return of funds for Student A timely. Recommendation: We recommend both the enrollment services and the financial aid departments closely follow their internal control procedures to ensure all status changes are reported timely. Views of responsible officials: Management agrees there was a lapse in controls surrounding the process of identifying withdrawn students. New and revised controls will be implemented to ensure timely processing of status changes and return of funds calculations. These controls include establishing an electronic form and work flow to ensure enrollment services and financial aid departments are notified of all drops, withdrawals, and leave of absences, performing a weekly review of students who have earned zero units in order to identify unofficial withdrawals and a review by the Director of Financial Aid of all drops, even those that do not require a return of funds calculation.
Show full finding ▾Hide full finding ▴FINDING 2020-001 ? Special Tests and Provisions ? Enrollment Reporting and Return of Title IV Funds ? Significant Deficiency in Internal Controls and Instance of Non-Compliance (See Schedule of Findings and Questioned Costs for table) Criteria: The National Student Loan Data System (?NSLDS?) is the Department of Education?s (?ED?s?) centralized database for students? enrollment information. In accordance with the NSLDS Enrollment Reporting Guidelines (Guide), published by ED, the timeliness of reporting is important to ensure that students receive their entitled deferment benefits and it provides Congress with necessary enrollment and graduation rates of grant and loan recipients. It is the Institute?s responsibility to update this information. The Guide also emphasizes that even if an Institute uses an enrollment reporting servicer, the Institute still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting roster files and for reporting any changes in student enrollment status in a timely manner. The Institute determines how often it receives the Enrollment Reporting roster file with the default set at every 2 months. Schools must complete and return within 30 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). Unless the Institute expects to complete its next roster within 60 days, the Institute must notify the lender or the guaranty agency within 30 days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (Direct Loan, 34 CFR section 685.309). Condition/Context: In testing individual student status changes, we selected a random sample of 18 students out of a population of 128 who had received student financial assistance and had withdrawn or graduated from the Institute during the 2019-2020 fiscal year as identified by internal records. We compared the enrollment information and withdrawal or graduation date per the Institute?s records to the information reported to NSLDS. We noted 2 selections were reported outside of required time frames. Student A withdrew on 4/10/2020 and the status change was reported to NSLDS on 7/13/2020, which is 93 days after the withdrawal date. The funds were returned outside of the required time frame for returning funds. Student B withdrew on 9/16/2019 and funds were returned timely on 9/20/2019. However, Student B?s status change was reported to NSLDS on 12/13/2019, which is 88 days after the withdrawal date. Cause: The delays were by a lapse in internal controls within the enrollment services department. Effect: Status changes for Student A and Student B were not reported to NSLDS timely. As a result, the financial aid office also did not process a return of funds for Student A timely. Recommendation: We recommend both the enrollment services and the financial aid departments closely follow their internal control procedures to ensure all status changes are reported timely. Views of responsible officials: Management agrees there was a lapse in controls surrounding the process of identifying withdrawn students. New and revised controls will be implemented to ensure timely processing of status changes and return of funds calculations. These controls include establishing an electronic form and work flow to ensure enrollment services and financial aid departments are notified of all drops, withdrawals, and leave of absences, performing a weekly review of students who have earned zero units in order to identify unofficial withdrawals and a review by the Director of Financial Aid of all drops, even those that do not require a return of funds calculation.
November 2, 2020 To: Moss Adams LLP Fr: Kristal Gama - Director of Financial Aid Lindsay Stadler - Registrar and Director of Student Information Management Re: Audit Findings for 2019-2020 Summary of new and revised controls used to ensure timely processing of enrollment changes and process R2T4 calculations accurately and efficiently: ? New staff have been hired in the Financial Aid Office and have been trained on the R2T4 CGU Policy and newly established business process. ? Established electronic form and flow process to ensure proper notification of drops, withdrawals and Leave of Absences with mechanisms to monitor timeliness, send notifications and push reminders. ? Revised business process to ensure that our Student Information System is accurately setup to perform necessary functions to: return funds to COD, verify loan has been adjusted, and ensure proper calculation on the students' account. ? Perform weekly review to identify student who have dropped to zero units. ? All drops, inclusive of R2T4 affected students, will be reviewed by the Director of Financial Aid. Revised R2T4 CGU POLICY In accordance with Federal Regulation 34 CFR 668.22, CGU is required to determine the earned and unearned portions of Title IV aid based on the date the student ceased attendance up to the 60% point in the payment period. After the 60% point in the payment period, a student has earned 100% of the Title IV funds and no Return of Title IV Funds (R2T4) calculation is required. However, we must still determine whether the student is eligible for a post-withdrawal disbursement (PWD). Although CGU has its own refund policy and schedule, the Financial Aid Office will determine the amount of Title IV aid the student has earned under the R2T4 calculation based on the date a student officially withdraws. Official withdrawal may occur several ways: via MyCGU portal (student drops to zero units) by notifying the Registrar?s Office or the financial aid office of their intent to withdraw. Leave of Absence Students who require a period of time away from their graduate studies may request a Leave of Absence (LOA). To be eligible for a Leave of Absence to count as a temporary interruption instead of a withdrawal, a student must meet all conditions listed in 34 CFR 668.22(d). A student who is granted a LOA and meets all the criteria in this section is not considered to have withdrawn, and no R2T4 is required. A student who fails to return from a LOA by the next semester is considered withdrawn and the withdrawal date reverts to the date the student began their LOA. For each student who is approved for a LOA, an electronic form will be circulated via AirSlate through the Financial Aid and Student Accounts Offices to ensure timely processing and monitoring as well as reminder to update NSLDS Enrollment manually. The AirSlate form is an improvement over previous processes as it will ensure that physical paperwork is not lost and the different offices involved (Registrar, Financial Aid, Student Accounts Offices) each have the ability to see where the document is in the workflow. PROCEDURES The Financial Aid Office receives paperwork or workflow triggers for an official withdrawal from the Registrar. If the student received or was eligible to receive federal aid at the time of withdrawal, then the R2T4 will be completed. Once the earned amount has been calculated, the school will return the funds listed in step 6 on the R2T4 worksheet. After the award adjustments are made, the Financial Aid Office will send an email to the student that indicates the amount the school returned to the Direct Loan program(s). Withdrawals via Drop on Student Portal On a weekly basis, the Assistant Director of Financial Aid in conjunction with the Registrar?s Office will run queries to identify students who have dropped to zero units on MyCGU student portal. The queries to identify the students are OSF_ZERO_UNIT_W_FED_AID, OSF_WITHDRAWS_WITH_AID and OSF_AUTH_W_NO_ENROLL. In reviewing the list generated by each query, we will gather all student data for the specified term and determine if an R2T4 is required. If a student is not receiving federal aid, then the calculation is deemed unnecessary and institutional aid is updated, if applicable. If the student received or was eligible for federal aid at the time of withdrawal, then the R2T4 information is documented in the ?Return of Title IV? record on the Common Origination & Disbursement (COD) portal. Once the amount the student earned is calculated, the school returns funds required listed in Step 6 of R2T4 Aid Worksheet. After the award adjustments are made, the Financial Aid Office will send an email (located on Z drive) which discloses what aid programs have been affected, how much the school has returned to said programs, as well as provide contact information for Student Accounts for any required payments. The Financial Aid Office will manually update NSLDS enrollment to reflect the student?s withdrawal. The withdrawal form will be returned to the Registrar?s office. The Registrar will forward the withdrawal form to the Student Accounts office to perform tuition recalculation. Students only have the ability to add or drop classes during the designated add/drop periods at the beginning of each session. Running the queries listed above on a weekly basis will ensure that any classes dropped that are specific to a later session within the term will be identified within the same week. The Registrar?s Office will also run a query (SR_WHEN_CLASSES_DROPPED) weekly to have another office checking to see if students have unofficially withdrawn due to dropping classes in a later session. Withdrawals via Add/drop Form Each time an Add/drop form is submitted to an academic department or to the Registrar?s Office it will now trigger an AirSlate workflow process, so that the Registrar, Financial Aid, and Student Accounts Offices will each receive email notifications that a workflow has begun and which requires action by that office. This system will enable all student services offices to keep track of where the request is in the process and take action more quickly, as the offices will not need to rely on paper being physically passed around each office to complete the workflow. Upon receipt of a withdrawal workflow form, Financial Aid will gather all student data for the specified term and determine if an R2T4 is required. If a student is not receiving federal aid, then the calculation is deemed unnecessary and institutional aid is updated, if applicable. If the student received or was eligible for federal aid at the time of withdrawal, then the R2T4 information is documented in the ?Return of Title IV? record on the Common Origination & Disbursement (COD) portal. Once the amount the student earned is calculated, the school returns funds required listed in Step 6 of R2T4 Aid Worksheet. After the award adjustments are made, the Financial Aid Office will manually update NSLDS enrollment to reflect the student?s withdrawal. The withdrawal workflow will be next sent to the Registrar?s office. The Registrar will complete additional tasks and then forward the withdrawal workflow to the Student Accounts office to perform tuition recalculation. R2T4 Policy revision date of October 26, 2020. The anticipated completion date for full implement all of the new control processes and revised R2T4 policy that is described above is November 9, 2020. Sincerely, Kristal Gama Lindsay Stadler
FAC accepted this audit on November 6, 2018 — management decision was due May 6, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on December 18, 2016 — management decision was due June 18, 2017.
GSA_MIGRATION
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2015-001
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