Concordia University Texas

Finding 2025-001: Significant Deficiency - Return of Title IV Funds

Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): Various Federal Award Number: Various Federal Award Year: June 30, 2025

Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds.

Condition/Context: For two of five students tested in the sample, the return of Title IV (R2T4) calculations were done late. The first student withdrew in January 2025 but the R2T4 calculation was not done until May 2025. The Pell grant was not originally disbursed but was later provided to the student as a post withdrawal disbursement (PWD) in July 2025. The second student had all loans returned when they withdrew in January and the R2T4 calculation was not done until September 2025, at which time it was determined the student did attend and earned some of the loan funds however, it was too late to disburse those funds as a PWD due to the regulations. The sample was not a statistically valid sample.

Cause: The University's processes and controls did not ensure that return of Title IV calculations were performed accurately or timely. The University noted personnel changes and training new staff contributed to the delays and errors.

Effect: Return of Title IV fund calculations were not completed timely. This resulted in one student not being able to receive the loan funds they should have been eligible for, and the other student did not receive timely disbursement of the grant funds they were eligible.

Questioned Costs: Total known questioned costs were $4,701 of Federal Direct Loan Program funds (ALN 84.268) and $206 of Pell (ALN 84.063). Likely questioned costs projected to the population of $27,400 for Federal Direct Loan Program and $1,200 for Pell.

Recommendation: The University should revise its procedures and controls surrounding withdrawals and R2T4 calculations to ensure they are completed accurately and timely.

Management's Response: The University agrees with the finding. The University is currently working with the IT officers to develop a more automatic process for R2T4 calculations and processing.

Finding 2025-002: Significant Deficiency - Gramm Leach Bliley Act

Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): Various Federal Award Number: Various Federal Award Year: June 30, 2025

Criteria: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). In 2021, the Federal Trade Commission issued final regulations that altered the current required elements of an information security program and added several new elements. Under the regulations, institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The written information security program for institutions must address all elements that apply. The elements for the information security programs set forth in this section 16 CFR 314.4 are high-level principles that set forth basic issues the programs must address, and do not prescribe how they will be addressed.

Condition/Context: The University did not have updated procedures and processes in place for certain required GLBA elements.

Cause: The University noted that several items required are in process or only partially completed.

Effect: Failure to comply with the requirements of GLBA standards put the University out of compliance with requirements and potentially at risk of compromising consumer, nonpublic personal information.

Questioned Costs: Not applicable.

Recommendation: It is recommended that the University update policies and procedures to ensure compliance with the GLBA regulations.

Management's Response: The University agrees with the finding. The University has begun reviewing its policies with the IT department and will be developing a plan that will provide detailed updates to the policies and procedures in accordance with the regulations.

Finding 2024-001: Significant Deficiency - Title IV Credit Balances Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024 Criteria: Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges, up to $200 of prior year, or future charges as noted in the regulations at (34 CFR 668.165(b)). Condition/Context: For 7 of 25 students tested, the students’ Title IV credit balances on their accounts were held for longer than the 14-day maximum, without student or parent authorization. The sample was not a statistically valid sample. Cause: The University's controls surrounding Title IV credit balances being paid timely or being held only when authorized by the student/parent did not detect or appropriately handle the Title IV credit balances. Effect: Title IV credit balances were held without student/parent authorization longer than the 14-day maximum. Questioned Costs: Total questioned costs were $27,834 of Federal Direct Student Loan funds (ALN 84.268). Recommendation: The University should revise its procedures to ensure Title IV credit balances are paid timely or student/parent authorizations to hold funds are obtained. Management's Response: The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2025 terms and new procedures will be put in place for the Fall 2025 term.

Finding 2024-002: Significant Deficiency – Enrollment Reporting Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.268 Federal Award Number: P268K242266 Federal Award Year: June 30, 2024

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address.

Condition/Context: For 1 of the 28, students who were tested, the incorrect withdrawal effective date was reported to NSLDS. That student's status was also not reported to NSLDS within 60 days. The sample was not a statistically valid sample.

Cause: The University's processes did not ensure accurate and timely reporting to NSLDS.

Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate.

Questioned Costs: Not applicable.

Context: Not applicable.

Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations.

Management's Response: Although enhanced monitoring processes were in place to ensure integrity and punctuality of data reported to the National Student Data Loan System, the University experienced challenges in timely reporting due to staff turnover. The enhanced monitoring and reporting processes have been updated and documented and the University built redundancy into the staffing model to prevent future discrepancies.