WAYLAND BAPTIST UNIVERSITY

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 (Student Financial Assistance Cluster) Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeated findings with the Department of Education regulations. This is due to limitations within the financial aid system, the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs with significant FAFSA and regulation changes, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing and respond to changes in legislation. The financial aid department continues to train new staff. The system used for student financial aid and enrollment reporting has limitations related to regulation changes. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system to allow for more automated packaging and adjust the double checking rules to flag the administrator if packaging may need to be adjusted after changed have occurred. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The NSLDS enrollment status effective date for withdrawals was not accurately sent to NSLDS from the system. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 75 students tested, 6 students had incorrect effective dates reported for their enrollment status, ranging from 13 to 84 days different. All of these students were official and unofficial withdrawals. Five of the students were corrected during the audit process. Cause: The system tracks the last date of attendance for certain classes, and professors track attendance for other classes, and not all dates are reported within one system to pull for NSLDS enrollment reporting. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes - 2024-001 Recommendation: We recommend the University put a system in place to ensure that the date being reported to NSLDS as the effective date of withdrawal is the actual last date of attendance for the student, that the University is completing reconciliations of enrollment status periodically, and that the University is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate and Untimely Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return the correct amount of unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 19 students, 3 students who withdrew during the audit period tested had funds returned late, ranging from 14 to 31 days. 1 of 19 withdrawals tested had a typo in the actual amount returned by over returning 3 dollars of Pell. All students were corrected during the audit process. Cause: These were oversights by the University. Effect: The unearned Title IV funds were returned late. Identification as repeat finding, if applicable: Yes - 2024-002 Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Students were not initially appropriately awarded subsidized aid based on need. Criteria: 34 CFR 685.203 Questioned Costs: $0 Context: 4 students out of 61 were under awarded subsidized loans based on need analysis and year of enrollment. These students were corrected during the audit process by reallocating unsubsidized loans to subsidized loans for a total of $5,010 reallocated. One of these four students was also under awarded unsubsidized loans. Due to the loan period, the University could not originate the loan to correct the student. Cause: There is a manual review process that did not catch these students. Effect: Students did not receive subsidized federal aid for which they were eligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: 4 students out of 50 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: All four students were under awarded Pell based on the number of credits they began attendance with, for a total of $2,183. All four students were corrected during the audit process. Cause: These were oversights by the University. Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: Yes - 2024-003 Recommendation: We recommend a process be used 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.

Incorrect Resolution of ISIR Aggregate Limits Flag Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: 2 out of 61 students had incorrect resolutions to the ISIR flag for aggregate loan limits. Criteria: 34 CFR 685.203(d) Questioned Costs: $0 Context: Out of 61 students tested for ISIR flags, 2 were underawarded Pell and loans based on the remaining eligibility. This resulted in an underaward of Pell of $184 which was corrected during the audit. There was also an under award of $553 of subsidized loans and $1,333 of unsubsidized loans that could not be originated due to being past the loan period. Cause: For one student, the initial ISIR received had the aggregate limits flag and was resolved. The second ISIR received did not resolve the flags, and no aid was disbursed. For the second student, there was an incorrect proration of loans for graduation as well as an incorrect resolution of the remaining unsubsidized eligibility. Effect: Students were not resolved correctly, resulting in loss of federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University review the way the system is flagging aggregate limits and resolutions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 91 students tested, 8 students were not properly reported to NSLDS. All of these students either withdrew between semesters or during a semester. The students have not yet been corrected. Cause: The system tracks the data needed for enrollment reporting, but somehow with the third-party servicer, these were not properly reported to NSLDS. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2023-003, 2022-003, 2021-005, 2020-002, and 2019-001. Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: There were two incorrect calculations of returned funds for students that withdrew during the term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 37 students, 2 students who withdrew had incorrect calculations. One student was not offered a post-withdrawal disbursement (PWD) of Pell when they attended less than half time in the spring, and one student had an incorrect last date of attendance used in the calculation. These students were not yet corrected during the audit process. Cause: These were oversights by the University. Effect: Incorrect amounts of federal funding were returned. One PWD of Pell was $76 less than the student was eligible for and a Pell PWD of $152 was not paid to one student. Identification as repeat finding, if applicable: Yes, 2023-002, 2022-002, 2021-004, and 2020-003. Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Two students out of 60 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $925 Context: One student was inadvertently awarded and paid Pell for one more class than they attended as they started in 11 hours instead of 12 resulting in an overaward of $925. This was corrected during the audit. One student was half time in summer and was not picked up to be paid Pell for the summer term, resulting in an underaward of $1,849. This student was corrected during the audit. Cause: These were oversights in the cleanup reports run. Effect: There was an incorrect amount of Pell paid to these two students. Identification as repeat finding, if applicable: Yes, 2023-005 and 2022-005. Recommendation: We recommend a process be used 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.

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception. Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-004 Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Documentation of Reconciliations DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Reconciliations were not available to review on a student-by-student basis year to date. Criteria: 34 CFR 668 Subpart L Questioned Costs: $0 Context: Reconciliations are required to be maintained on a monthly basis including year to date information for FDL and Pell. These reconciliations have been done on screen with each batch disbursement and in aggregate but not at the student-by-student detail year to date. Because the University has a large enrollment, student by student manual reconciliations are not time effective. Cause: The University’s system does not currently allow importing of student files from Common Origination and Disbursement (COD) to complete the reconciliations in a time effective manner. Effect: The documentation for reconciliations is not available year to date. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not return all required federal funds timely when a student withdrew or stopped attending. Additionally, the University did not make the post-withdrawal disbursements timely. Criteria: 34 CFR 668.22 Questioned Costs: $2,069 Context: Out of 30 students tested, 3 students who withdrew during the audit period had funds returned late ranging from 14 to 252 days late but within the audit period, and 2 students had post-withdrawal disbursements made more than 180 days after the eligible date. One additional student was eligible for a post-withdrawal disbursement which had not been made during the fiscal year, and at the time of the report, was past the number of days allowed for a disbursement. Five students out of the 6 listed were before the spring 2023 semester. The return that was 14 days late was in the spring 2023 semester. All students that could be corrected during the audit process were corrected. Cause: There has been significant turnover in the financial aid department at the University during the period under audit. Effect: Federal funding was not returned timely. The post withdrawal disbursements made late were Pell disbursements totaling $1,536. Identification as repeat finding, if applicable: Yes, 2022-002, 2021-004, and 2020-003. Recommendation: We recommend that the University continue to provide additional training for counselors performing R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Award Year Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 84 students tested, there were 12 students who withdrew whose enrollment status did not reflect that they had withdrawn in a timely manner. The students have not been corrected yet. Cause: The system tracks the data needed for enrollment reporting, and this data was submitted to National Student Clearinghouse (NSC). The transfer of data from NSC to NSLDS did not reflect these students as withdrawn. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2022-003, 2021-005, 2020-002, and 2019-001. Recommendation: We recommend the University work with NSC to determine why the dates transferred to NSLDS did not reflect the withdrawal dates. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew, whether officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379-Student Financial Assistance Cluster 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 all systems containing personally identifiable information (PII), implemented continuous monitoring or once a year penetration testing and twice a year vulnerability scanning, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board. Cause: The University has been in the process of addressing and documenting compliance with the requirements of GLBA. As this work has progressed over the last couple of years, the standards were updated, and the University has incorporated those updates into its roadmap for security. 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 allocate sufficient resources to address all requirements of GLBA. We commend the University for the work completed on GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: 4 students out of 60 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $2,280 Context: Two students were inadvertently awarded and paid Pell for more classes than they attended, resulting is $2,280 overawards. This was not corrected during the audit. One student was not paid Pell for all classes attended, resulting in an underaward of $381. One student was paid the fall 2022 Pell award but was not paid for spring and summer. This student was corrected during the audit process. Cause: There was not an internal report run to verify that all changes in attendance resulted in the students being paid Pell for the classes in which they began attendance. Effect: Pell was not awarded correctly based on enrollment status, resulting in overawards to some students and underawards to other students. Identification as repeat finding, if applicable: Yes, 2022-005. Recommendation: We recommend a process be used 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.

Need Analysis and Loan Proration DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not appropriately awarded subsidized loans based on need. Where there was a change in the student's cost of attendance or other aid, a recalculation of need based aid was not performed to catch adjustments before a second disbursement of aid was made. One student who was in the final semester to graduate did not have loan appropriately prorated. Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 685.203 Questioned Costs: $394 Context: Out of 60 students, one student was not awarded aid appropriately based on need analysis. The student had eligibility for subsidized loans but was not awarded up to need, totaling $438. This student was corrected during the audit. One student’s proration was done in aggregate for loans instead of individually between subsidized loans and unsubsidized loans, resulting in an overaward of subsidized loans by $394. This student was not corrected during the audit process. Cause: Additional scholarships were added after federal aid awarded but before the second disbursement was made. The validation check before the second disbursement was made did not catch these. The proration calculation was performed based on the total of $7,500 instead of $5,500. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Yes, 2022-004 and 2021-008. Recommendation: We recommend 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 a student's cost of attendance is adjusted to review need analysis and update awarding as needed. For loan proration, we recommend the University prorate remaining loans individually between subsidized and unsubsidized programs. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.