UNIVERSITY OF DENVER

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: • 84.268 – Federal Direct Loans • 84.063 – Federal Pell Grant Program

Federal Award identification Number • P063P240063 - 2025 • P268K250063 – 2025

Award Period: July 1, 2024 – June 30, 2025

Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance

Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days.

Condition: As part of the August 6, 2025, roster submission of enrollment status changes, the University reported an enrollment status change of Full-Time to Graduated with an effective date of December 18, 2024, for a student who received a Direct Student Loan during the fiscal year. We measured the results of our testing against the Department of Education's 60-day timeframe for submitting roster files. The University reported the enrollment status change for this student 231 days after the effective date, or 171 days after the 60-day timeframe for submitting roster files.

Questioned costs: None

Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan and had an enrollment status change during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days.

Cause: The University of Denver did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Student Financial Aid program. During the Gainful Employment/Financial Value Transparency reporting period, a discrepancy was identified regarding a student incorrectly reported to NSLDS as “withdrawn” rather than “graduated”. Upon investigation, the Office of the Registrar determined that the Autumn 2024 graduation file for the College of Law had not been submitted to the National Student Clearinghouse. This omission was due to a process gap: the College of Law’s degree conferral timeline differs from the University’s standard Undergraduate and Graduate schedules, and previous protocols relied on passive notification rather than active coordination.

Effect: Enrollment reporting assists in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. For recipients of Pell Grants, timely enrollment reporting by institutions assists with their eligibility, future disbursements amounts, and continued access to Student Financial Aid.

Repeat finding: No

Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. This could include requiring protocols to include an active coordination of graduation files, including those with differing conferral timelines.

Views of Responsible Officials: The University agrees with the audit finding.

Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Code of Federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party.

Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued.

Questioned costs: $158,443

Context: During our testing, it was noted 69 out of 400 outstanding checks over 240 days old were Title IV federal funds checks that were over the 240-day limit.

Cause: The University did not have adequate processes in place to monitor outstanding Title IV disbursement checks throughout the year.

Effect: The University is not in compliance with Department of Education requirements.

Repeat finding: No

Recommendation: [the auditor] recommends that the University review the requirement and implement a control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education.

Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 674.19(e) states that Institutions must retain original, true, and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. An original electronically signed MPN must be retained by the institutions for three years after all the loans made on the MPN are satisfied. Condition: During our testing, we noted 2 of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Context: We tested record retention for 40 student Perkins Loans. Of the 40, we identified 2 student’s MPN were not maintained for loans with outstanding balances as required by the regulations. Questioned costs: None. Cause: The record was lost or misplaced.

Effect: The University was not in compliance with the Perkins recordkeeping regulations. Repeat Finding: No. Recommendation: We recommend that the University implement procedures to ensure all documentation is being maintained as required by federal regulations.

Views of responsible officials and management’s response: The University agrees with the finding.

Criteria or specific requirement: Per the Department of the Treasury Office (the Department), state, territorial, metropolitan city, county, Tribal governments, and Non-Entitlement Units that receive funding from the State and Local Fiscal Recovery Funds Programs are required to meet compliance and reporting responsibilities. This supports transparency, responsibility, and equity in use of these vital resources. More specifically, the Department’s Corona virus State and Local fiscal Recovery Funds Compliance and Reporting Guidance, Part I, Section C.3 states that generally, recipients must submit one initial Interim Report, quarterly or annual Project and Expenditure reports which include subaward reporting, and in some cases annual Recovery Plan reports.

Given the University received its SLFRF passed through the State of Colorado, the University was to follow reporting requirements passed to it by the State. Per the Grant Agreement with the State of Colorado, Section 6.A, the grantee shall submit, on a quarterly basis, a written report specifying progress made for each specified performance measure and standard in the agreement. Progress reports shall be submitted to the State no later than ten Business Days following the end of each calendar quarter or at such time as otherwise specified by the State. Condition: During testing to determine if the required quarterly were both timely and accurate/supported by the University’s books and records, we noted that quarterly reports were not being filed timely. Of the report ultimately submitted, confirmation of the submission was not maintained, and we could not test the accuracy of the submission. Context: Based upon the timing of the disbursements of the award, we estimate one report should have been submitted ten business days after June 30, 2023. This report was not submitted until the State of Colorado contacted the University for the report in October 2023. The University then submitted the information; but the report was not retained for audit/testing. Questioned costs: None. Cause: The University did not have a process in place to implement a reporting process for these new monies.

Effect: The University was not in compliance with regulatory provisions as it pertains to the quarterly reporting requirement. Repeat Finding: No Recommendation: When new grants and awards are received, the University should designate ownership of compliance, including reporting requirements. Processes and controls should be implemented to ensure accurate and timely reporting occurs as required by grant requirements. In addition, reports and supporting documentation should be retained for audit and review purposes.

Views of responsible officials and management’s response: The University agrees with the finding.