Schreiner University

Special Tests and Provisions – Return of Title IV U.S. Department of Education, Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program, Assistance Listing Number 84.007 Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.033 Federal Work-Study Program, Assistance Listing 84.379 Teacher Education Assistance for College and Higher Education Grants Program Year 2024–2025 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Per 34 CFR §668.22, institutions are required to determine the amount of Title IV funds that must be returned when a student withdraws from the institution before completing the payment period or period of enrollment. The calculation must be performed accurately and timely using the prescribed formula to ensure compliance with federal regulations. Condition: The University's processes did not ensure the calculations performed to calculate required return of funds were accurate. Questioned Costs: $0 Context: Out of the population of 35 students with withdraw status subject to potential returned funds, a sample of four students were selected for testing. For two of the four samples tested, the University incorrectly calculated the amount of Title IV funds to be returned. Effect: The University returned an incorrect amount of Title IV funds to the Department of Education for the affected students, potentially resulting in noncompliance with federal regulations and financial liability. Cause: The errors appear to be the result of manual data entry and insufficient review controls within the financial aid office’s Return of Title IV funds process. Recommendation: We recommend the University strengthen its internal controls over the Return of Title IV funds calculation process. This should include implementing a secondary review of all calculations and ensuring accurate documentation of withdrawal dates and payment period parameters. Views of Responsible Officials: Management concurs with the finding and recommendation. Further information on the corrective action plan will be provided by management.

Special Tests and Provisions – Enrollment Reporting U.S. Department of Education, Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program Program Year 2024–2025 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Per 2 CFR §200.303, 34 CFR 685.309, OMB No. 1845-0035 and the Federal Student Aid Handbook, institutions are required to report accurate and timely enrollment status changes, including graduation, to the NSLDS via the National Student Clearinghouse or other reporting mechanisms. Accurate reporting ensures proper administration of Title IV funds and prevents inappropriate loan deferments or repayments. Condition: The University did not ensure that all graduation data was accurately transmitted and reflected in the National Student Loan Data System (NSLDS). Questioned Costs: $0 Context: Out of the population of 167 students subject to enrollment reporting, a sample of 17 students were selected for testing. For 1 of the 17 students tested, NSLDS did not reflect the student’s graduation status on campus or program students in which the University’s records reported graduated. Effect: Failure to report accurate enrollment status may result in incorrect deferment or repayment statuses for student borrowers, potentially impacting loan servicing and compliance with federal regulations. Cause: The errors appear to be the result of a lapse in control by the University to ensure all graduation data was accurately transmitted and reflected in the NSLDS. Recommendation: We recommend the University enhance its controls over the enrollment reporting process to ensure that all graduation data is accurately and timely reported to the NSLDS. This may include periodic reconciliations between internal records and NSLDS data and follow-up procedures for discrepancies. Views of Responsible Officials: Management concurs with the finding and recommendation. Further information on the corrective action plan will be provided by management.

Criteria: Institutions must report all loan disbursements and submit required records to the Common Origination and Disbursement System (COD) within 15 days of disbursement (OMB No. 1845-0021). Direct Loan School Account Statement (SAS) reconciliations are a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the Common Origination and Disbursement (COD) System on an ongoing basis. Condition/Context: For the period under audit, supporting evidence that SAS data files were reconciled to the University’s financial records could not be provided. Cause: The Universitys SAS data files and their reconciliation to internal financial records were not properly documented and retained. Effect: Lack of reconciliation procedures could result in improper data and within the COD system and noncompliance in cash management of the direct loan program and/or noncompliance with disbursement reporting requirements. Questioned Costs: Not applicable Recommendation: The University should put into place policies and procedures to ensure compliance with federal grant reporting requirements, including documenting and retaining monthly SAS reconciliations. Management’s Response: Management understands the finding and will seek to add documentation control procedures to ensure evidence of reconciliations are maintained.

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: There was a lack of controls over the process of reporting student enrollment data to NSLDS. The following exceptions were noted in our testing of enrollment status change reporting for 25 students:  Eight students' status change effective dates reported to National Student Loan Database System (NSLDS) did not agree to the support provided from the University's system at either the campus level, program-level or both.  Three of the students mentioned above, also had incorrect status changes reported the NSLDS at the program-level. The sample was not a statistically valid sample. Cause: The University's controls surrounding NSLDS enrollment reporting did not detect or appropriately handle errors and omissions in the reporting. Effect: Incorrect information was reported to NSLDS. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students. Controls should be implemented that include review of data submitted to NSLDS and reconciliation of the information NSLDS retains to the underlying enrollment data should be performed. Management's Response: The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.