Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Federal Pell Grant Program (ALN#: 84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Reporting - Common Origination and Disbursement ("COD") System - All institutions receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions must report student payment data no earlier than 7 days before and no later than 15 days after the institution makes a payment or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data (ED Notice, July 14, 2020, Federal Register (85 Federal Register 42368)). Condition: Instances were identified where the student payment data was not submitted within the required timeframe. Cause: Insufficient administrative oversight and insufficient internal control with respect to disbursement compliance requirements. Effect: The College was not in compliance with the Pell reporting compliance requirements. Questioned Costs: None. Context: For 27 of 40 students selected for testing, the student payment data was not submitted within the required timeframe. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-003. Recommendation: We recommend the College enhance its procedures and internal controls to ensure Pell payment data is submitted to the Department of Education within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: It is a compliance requirement to report Pell files to the Department of Education through the COD system. 27 student files were identified as a compliance finding out of the 40 students sampled. This is a repeat finding from the prior year (June 30, 2021) but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented practices whereby the office is now receiving and sending files to the COD system daily. This allows for resolving issues/rejects much sooner and within the 15-day timeframe. The Director has also conducted training with financial aid staff to emphasize the importance of sending files and resolving issues in a timely fashion.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Enrollment Reporting - The College is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: Instance was identified where the College failed to submit timely notification to the NSLDS website for a student who graduated during the year. Cause: Lack of administrative oversight with respect to enrollment reporting requirements. Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 21 students selected whose status changed during the year, the College failed to submit a timely notification to the NSLDS website. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Registrar?s Office revised its monthly processes and procedures guide to include better monitoring of any potential errors with NSLDS reporting. The Registrar submits an enrollment report on the 15th day of every month to the Clearinghouse. Once an email is received from the Clearinghouse allowing the Registrar to view any errors on the website, the Registrar will check the NSLDS portion of the website to see if any corrections are necessary. These procedures were followed in regard to the finding reported. The College is not aware of why the student?s record was not found within the NSDLS website however, it will be more diligent in its monitoring of this activity going forward.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Students Loan Data System (the ?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert during the 7-day period or if it obtains the student's financial aid history by accessing the NSLDS Financial Aid Professional website. When a school receives an alert from NSLDS, before making a disbursement of Title IV aid, it must determine if the change to the student's financial aid history affects the student's eligibility (34 CFR section 668.19). Condition: Instances were identified where the College disbursed Title IV aid prior to informing NSLDS about transfer students. Cause: Lack of administrative oversight and insufficient internal controls with respect to transfer monitoring requirements. Effect: The College was not in compliance with the transfer monitoring requirements. Questioned Costs: None. Context: For 2 of 2 students selected for testing, the College did not properly inform NSLDS of transfer students prior to disbursing Title IV aid. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-005. Recommendation: We recommend the College enhance its procedures and internal controls to ensure compliance with transfer monitoring requirements. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges the requirement that schools obtain financial aid history information for their transfer students. 2 student files were identified as a compliance finding out of the 2 students sampled. This is a repeat finding from the prior year (June 30, 2021) but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures where it will work closely with the Office of Admission and update NSLDS manually to ?inform? it of the transfer students applying to PC mid-year. This is a relatively small group of students. For those students included on a school?s ?Inform? list, NSLDS ?Monitors? changes to the student?s financial aid history that have occurred since the latest ISIR for the student was generated and sent to the school. NSLDS will continue to monitor changes to the student?s financial aid history, and alert the school of any subsequent relevant changes. A staff member in the Office of Financial Aid will be assigned to review the Transfer Monitoring files.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(2)(i)) require that the institution notify the student, or parent, in writing of (1) the anticipated date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Instance was identified where the required loan disbursement notification was not sent to the parent borrower. Cause: Lack of administrative oversight with respect to loan disbursement notification requirements. Effect: Parent was not properly notified of award disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 1 of 40 students, the College did not send the required loan disbursement notification to parent borrower. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-006. Recommendation: We recommend the College enhance its policies and procedures over award notifications to ensure that notifications are sent to parent borrowers within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: The College recognizes that when Direct Loan funds are being credited to a student?s ledger account (except in the case of loan funds made as part of a post-withdrawal disbursement), the school must notify the borrower in writing (paper or electronically) of the: ? anticipated date and amount of the disbursement; ? student?s or parent?s right to cancel all or a portion of a loan, loan disbursement, disbursement and have the loan proceeds returned to the Department; and ? procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the loan or loan disbursement. The timing of a loan notification varies depending on whether a school obtains affirmative confirmation from a student that he or she wants a loan. Affirmative confirmation is a process under which a school obtains written confirmation of the types and amounts of Title IV loans a student wants for the period of enrollment before the institution credits the student?s account with those loan funds (34 CFR 668.165(a)(6)). Presbyterian College requires students to accept Direct Loan awards in BannerWeb so notifications are sent according to requirements when a student actively confirms the loan. Disbursement notifications were sent to students after each disbursement during the 2021-2022 academic year; however, the parent was not directly notified of a PLUS loan disbursement. For the 2023-2024 academic year, a PLUS Loan Form has been created and will be sent to the parent borrower to confirm the amount requesting. As of March 6, 2023, notifications are being created to notify parents with PLUS loans of disbursement and their rights.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Enrollment Reporting - The College is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: Instance was identified where the College failed to submit timely notification to the NSLDS website for a student who graduated during the year. Cause: Lack of administrative oversight with respect to enrollment reporting requirements. Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 21 students selected whose status changed during the year, the College failed to submit a timely notification to the NSLDS website. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Registrar?s Office revised its monthly processes and procedures guide to include better monitoring of any potential errors with NSLDS reporting. The Registrar submits an enrollment report on the 15th day of every month to the Clearinghouse. Once an email is received from the Clearinghouse allowing the Registrar to view any errors on the website, the Registrar will check the NSLDS portion of the website to see if any corrections are necessary. These procedures were followed in regard to the finding reported. The College is not aware of why the student?s record was not found within the NSDLS website however, it will be more diligent in its monitoring of this activity going forward.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student?s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student. Condition: Instance was identified where incorrect unearned amount was returned to the COD. Cause: Lack of administrative oversight with respect to Return of Title IV (?R2T4?) calculation. Effect: Error in Title IV funds returned to the COD. Questioned Costs: Amount below reportable threshold. Context: For 1 of 2 students selected for testing, the College did not return the correct amount to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College utilize R2T4 worksheets and complete timely review of R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: As of September 2022, the Office of Financial Aid began utilizing the R2T4 Worksheet found on COD. This more clearly and specifically states the net total that should be returned.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (ALN #84.425E) and Institutional Portion (ALN #84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Annual Reporting for HEERF II and III - The HEERF Year 2 Annual Performance Report was required to be submitted to the Department of Education via the Annual Report Data Collection Tool by May 6, 2022 to cover the reporting period January 1, 2021 through December 31, 2021. The Department of Education collected information to provide the public with insight into how funds were used by institutions to support students and educators addressing the impact of COVID-19, and for helping to ensure accountability with respect to federal funds. Condition: Instances were identified where certain amounts reported within the HEERF Year 2 Annual Performance Report were inaccurate. Cause: Lack of administrative oversight with respect to amounts to be input within certain fields of the HEERF Year 2 Annual Performance Report. Effect: The College is not in compliance with HEERF reporting requirements. Questioned Costs: None. Context: The amount of Emergency Financial Aid Grants applied to satisfy student?s outstanding balance was double-counted for the period January 1, 2021 through December 31, 2021, which further resulted in the amount of grants disbursed to students through all HEERF funds to be overstated. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-010. Recommendation: We recommend the College enhance its procedures to ensure that the appropriate amounts are reported with each field of required HEERF reports. Views of Responsible Officials and Planned Corrective Actions: When preparing the HEERF Year 2 Annual Performance Report, a question was answered incorrectly due to a misinterpretation of what information the question was requesting. The College will put in place procedures to ensure future HEERF reports are prepared correctly.
Federal Program Information: Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (ALN #84.425E) and Institutional Portion (ALN #84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Annual Reporting for HEERF II and III - The HEERF Year 2 Annual Performance Report was required to be submitted to the Department of Education via the Annual Report Data Collection Tool by May 6, 2022 to cover the reporting period January 1, 2021 through December 31, 2021. The Department of Education collected information to provide the public with insight into how funds were used by institutions to support students and educators addressing the impact of COVID-19, and for helping to ensure accountability with respect to federal funds. Condition: Instances were identified where certain amounts reported within the HEERF Year 2 Annual Performance Report were inaccurate. Cause: Lack of administrative oversight with respect to amounts to be input within certain fields of the HEERF Year 2 Annual Performance Report. Effect: The College is not in compliance with HEERF reporting requirements. Questioned Costs: None. Context: The amount of Emergency Financial Aid Grants applied to satisfy student?s outstanding balance was double-counted for the period January 1, 2021 through December 31, 2021, which further resulted in the amount of grants disbursed to students through all HEERF funds to be overstated. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-010. Recommendation: We recommend the College enhance its procedures to ensure that the appropriate amounts are reported with each field of required HEERF reports. Views of Responsible Officials and Planned Corrective Actions: When preparing the HEERF Year 2 Annual Performance Report, a question was answered incorrectly due to a misinterpretation of what information the question was requesting. The College will put in place procedures to ensure future HEERF reports are prepared correctly.
Federal Program Information: Schedule of Expenditures of Federal Awards (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Reporting- The auditee must prepare a schedule of expenditures of Federal awards (the ?SEFA?) for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502 Basis for determining Federal awards expended. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For Research and Development (?R&D?), total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the passthrough entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the Assistance Listing number or other identifying number when the Assistance Listing information is not available. For a cluster of programs also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in 2 CFR 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule. (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the auditee elected to use the 10% de minimis cost rate as covered in 2 CFR 200.414. Condition: The SEFA as prepared by management did not originally include one federal grant with federal expenditures to be reported within the 2022 SEFA. Cause: Lack of administrative oversight and insufficient internal controls with respect to preparation of the SEFA. Effect: The original draft SEFA was incomplete. Questioned Costs: None. Context: The original draft SEFA was incomplete. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-001. Recommendation: We recommend the College enhance its procedures and internal controls with respect to preparation and review of the SEFA. Views of Responsible Officials and Planned Corrective Actions: The grant included in the finding was received from a local government entity which did not communicate any reporting requirements associated with the grant. The College will be more vigilant in future years in assessing any grants received for inclusion on the SEFA.
Federal Program Information: Federal Perkins Loans (ALN #84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Perkins Loan Record Retention: An institution shall keep the original promissory notes and repayment schedules until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. (i) An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. (ii) If a promissory note was signed electronically, the institution must store it electronically and the promissory note must be retrievable in a coherent format. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied. 34 CFR 674.19(e)(4) Condition: Instance was identified where a Perkins master promissory note could not be located by the College. Cause: Lack of administrative oversight with respect to Perkins Loan record retention. Effect: The College is not in compliance with Perkins Loan record retention requirements. Questioned Costs: None. Context: For 1 of 25 students selected for testing, the College was unable to locate Perkins master promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College keep inventory of Perkins MPN records kept on campus. Views of Responsible Officials and Planned Corrective Actions: The College maintains all Perkins promissory notes in alphabetical order, in a dedicated filing cabinet, in a fireproof vault. This finding relates to a promissory note that was signed in 1987 and the College is not aware of what may have caused this Promissory note to be misplaced. No further action is planned by Management as the Perkins Loan Program expired on September 30, 2017 and no additional Perkins Loan disbursements were made by the College since the Program?s expiration.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Federal Pell Grant Program (ALN#: 84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Reporting - Common Origination and Disbursement ("COD") System - All institutions receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions must report student payment data no earlier than 7 days before and no later than 15 days after the institution makes a payment or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data (ED Notice, July 14, 2020, Federal Register (85 Federal Register 42368)). Condition: Instances were identified where the student payment data was not submitted within the required timeframe. Cause: Insufficient administrative oversight and insufficient internal control with respect to disbursement compliance requirements. Effect: The College was not in compliance with the Pell reporting compliance requirements. Questioned Costs: None. Context: For 27 of 40 students selected for testing, the student payment data was not submitted within the required timeframe. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-003. Recommendation: We recommend the College enhance its procedures and internal controls to ensure Pell payment data is submitted to the Department of Education within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: It is a compliance requirement to report Pell files to the Department of Education through the COD system. 27 student files were identified as a compliance finding out of the 40 students sampled. This is a repeat finding from the prior year (June 30, 2021) but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented practices whereby the office is now receiving and sending files to the COD system daily. This allows for resolving issues/rejects much sooner and within the 15-day timeframe. The Director has also conducted training with financial aid staff to emphasize the importance of sending files and resolving issues in a timely fashion.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Enrollment Reporting - The College is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: Instance was identified where the College failed to submit timely notification to the NSLDS website for a student who graduated during the year. Cause: Lack of administrative oversight with respect to enrollment reporting requirements. Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 21 students selected whose status changed during the year, the College failed to submit a timely notification to the NSLDS website. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Registrar?s Office revised its monthly processes and procedures guide to include better monitoring of any potential errors with NSLDS reporting. The Registrar submits an enrollment report on the 15th day of every month to the Clearinghouse. Once an email is received from the Clearinghouse allowing the Registrar to view any errors on the website, the Registrar will check the NSLDS portion of the website to see if any corrections are necessary. These procedures were followed in regard to the finding reported. The College is not aware of why the student?s record was not found within the NSDLS website however, it will be more diligent in its monitoring of this activity going forward.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Students Loan Data System (the ?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert during the 7-day period or if it obtains the student's financial aid history by accessing the NSLDS Financial Aid Professional website. When a school receives an alert from NSLDS, before making a disbursement of Title IV aid, it must determine if the change to the student's financial aid history affects the student's eligibility (34 CFR section 668.19). Condition: Instances were identified where the College disbursed Title IV aid prior to informing NSLDS about transfer students. Cause: Lack of administrative oversight and insufficient internal controls with respect to transfer monitoring requirements. Effect: The College was not in compliance with the transfer monitoring requirements. Questioned Costs: None. Context: For 2 of 2 students selected for testing, the College did not properly inform NSLDS of transfer students prior to disbursing Title IV aid. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-005. Recommendation: We recommend the College enhance its procedures and internal controls to ensure compliance with transfer monitoring requirements. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges the requirement that schools obtain financial aid history information for their transfer students. 2 student files were identified as a compliance finding out of the 2 students sampled. This is a repeat finding from the prior year (June 30, 2021) but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures where it will work closely with the Office of Admission and update NSLDS manually to ?inform? it of the transfer students applying to PC mid-year. This is a relatively small group of students. For those students included on a school?s ?Inform? list, NSLDS ?Monitors? changes to the student?s financial aid history that have occurred since the latest ISIR for the student was generated and sent to the school. NSLDS will continue to monitor changes to the student?s financial aid history, and alert the school of any subsequent relevant changes. A staff member in the Office of Financial Aid will be assigned to review the Transfer Monitoring files.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(2)(i)) require that the institution notify the student, or parent, in writing of (1) the anticipated date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Instance was identified where the required loan disbursement notification was not sent to the parent borrower. Cause: Lack of administrative oversight with respect to loan disbursement notification requirements. Effect: Parent was not properly notified of award disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 1 of 40 students, the College did not send the required loan disbursement notification to parent borrower. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-006. Recommendation: We recommend the College enhance its policies and procedures over award notifications to ensure that notifications are sent to parent borrowers within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: The College recognizes that when Direct Loan funds are being credited to a student?s ledger account (except in the case of loan funds made as part of a post-withdrawal disbursement), the school must notify the borrower in writing (paper or electronically) of the: ? anticipated date and amount of the disbursement; ? student?s or parent?s right to cancel all or a portion of a loan, loan disbursement, disbursement and have the loan proceeds returned to the Department; and ? procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the loan or loan disbursement. The timing of a loan notification varies depending on whether a school obtains affirmative confirmation from a student that he or she wants a loan. Affirmative confirmation is a process under which a school obtains written confirmation of the types and amounts of Title IV loans a student wants for the period of enrollment before the institution credits the student?s account with those loan funds (34 CFR 668.165(a)(6)). Presbyterian College requires students to accept Direct Loan awards in BannerWeb so notifications are sent according to requirements when a student actively confirms the loan. Disbursement notifications were sent to students after each disbursement during the 2021-2022 academic year; however, the parent was not directly notified of a PLUS loan disbursement. For the 2023-2024 academic year, a PLUS Loan Form has been created and will be sent to the parent borrower to confirm the amount requesting. As of March 6, 2023, notifications are being created to notify parents with PLUS loans of disbursement and their rights.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Enrollment Reporting - The College is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: Instance was identified where the College failed to submit timely notification to the NSLDS website for a student who graduated during the year. Cause: Lack of administrative oversight with respect to enrollment reporting requirements. Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 1 of 21 students selected whose status changed during the year, the College failed to submit a timely notification to the NSLDS website. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: Registrar?s Office revised its monthly processes and procedures guide to include better monitoring of any potential errors with NSLDS reporting. The Registrar submits an enrollment report on the 15th day of every month to the Clearinghouse. Once an email is received from the Clearinghouse allowing the Registrar to view any errors on the website, the Registrar will check the NSLDS portion of the website to see if any corrections are necessary. These procedures were followed in regard to the finding reported. The College is not aware of why the student?s record was not found within the NSDLS website however, it will be more diligent in its monitoring of this activity going forward.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student?s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student. Condition: Instance was identified where incorrect unearned amount was returned to the COD. Cause: Lack of administrative oversight with respect to Return of Title IV (?R2T4?) calculation. Effect: Error in Title IV funds returned to the COD. Questioned Costs: Amount below reportable threshold. Context: For 1 of 2 students selected for testing, the College did not return the correct amount to COD. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College utilize R2T4 worksheets and complete timely review of R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: As of September 2022, the Office of Financial Aid began utilizing the R2T4 Worksheet found on COD. This more clearly and specifically states the net total that should be returned.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Verification - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (?ED?). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). The institution must (1) obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned; (2) match information on the documentation to the student aid application; (3) if necessary, submit data corrections to the central processor and recalculate awards; and (4) correctly code the student?s verification status in the Common Origination and Disbursement (?COD?) system for Pell Grants and Subsidized Direct Loans. Condition: Instance was identified where the College disbursed funds prior to completion of verification. Cause: Lack of administrative oversight with respect to verification. Effect: The College was not in compliance with verification requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the College disbursed funds prior to completion of verification and was not in compliance with the verification requirements. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-004. Recommendation: We recommend the College implement policies and procedures for verifying applicant information prior to disbursing funds. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instance was identified where the College did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students. Effect: The College was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 1 of 40 students selected for testing, the College did not issue the refund within the required 14 days. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-007. Recommendation: We recommend the College complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to ensure all FSA credit balances are refunded to students within the required timeframe.
Federal Program Information: Student Financial Assistance Cluster (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) Special Reporting ? Fiscal Operations Report and Application to Participate (?FISAP?): The Fiscal Operations Report and Application to Participate is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the Campus-Based programs in a prior award year. In addition, an institution uses the FISAP to request funds to participate in the Campus-Based programs for the upcoming year. The FISAP will ask generic questions about the institution as well as request information specific to each of the Campus-Based programs in which the institution participates. Specifically, the FISAP requires: 1. identifying information (e.g., name and address of the institution, OPEID, financial aid administrator and chief executive officer information); 2. the amount requested for the next year for each Campus-Based program; 3. information on enrollment, length of terms, and the number of students enrolled and expected to enroll; 4. the total Pell Grant expenditures; 5. Report on all annual and cumulative Perkins Loan activity (e.g., loan principal collected; loan principal cancelled due to a loan forgiveness program; any repayments of fund capital both to the government and to the institution); 6. FSEOG information (e.g., funds allocated to students, non-federal share of funds advanced to FSEOG recipients, administrative cost allowances); 7. Federal Work-Study information (e.g., amount of funds allocated to students, amount spent for summer employment, information about students employed in community service activities using FWS funds); and 8. the amount of money transferred between Campus-Based programs. 34 CFR 673.3, 674.19(d)(2), 675.19(b)(3), 676.19(b)(3) Condition: Certain key line items within submitted FISAP report did not agree to source documentation. Cause: Lack of administrative oversight with respect to data included within the FISAP report. Effect: The College is not in compliance with FISAP reporting requirements. Questioned Costs: None. Context: Errors identified within submitted FISAP report which did not reconcile to schedules and documentation used by the College to populate the FISAP. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that the FISAP is completed accurately prior to submission. Views of Responsible Officials and Planned Corrective Actions: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting.
Federal Program Information: Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (ALN #84.425E) and Institutional Portion (ALN #84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Annual Reporting for HEERF II and III - The HEERF Year 2 Annual Performance Report was required to be submitted to the Department of Education via the Annual Report Data Collection Tool by May 6, 2022 to cover the reporting period January 1, 2021 through December 31, 2021. The Department of Education collected information to provide the public with insight into how funds were used by institutions to support students and educators addressing the impact of COVID-19, and for helping to ensure accountability with respect to federal funds. Condition: Instances were identified where certain amounts reported within the HEERF Year 2 Annual Performance Report were inaccurate. Cause: Lack of administrative oversight with respect to amounts to be input within certain fields of the HEERF Year 2 Annual Performance Report. Effect: The College is not in compliance with HEERF reporting requirements. Questioned Costs: None. Context: The amount of Emergency Financial Aid Grants applied to satisfy student?s outstanding balance was double-counted for the period January 1, 2021 through December 31, 2021, which further resulted in the amount of grants disbursed to students through all HEERF funds to be overstated. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-010. Recommendation: We recommend the College enhance its procedures to ensure that the appropriate amounts are reported with each field of required HEERF reports. Views of Responsible Officials and Planned Corrective Actions: When preparing the HEERF Year 2 Annual Performance Report, a question was answered incorrectly due to a misinterpretation of what information the question was requesting. The College will put in place procedures to ensure future HEERF reports are prepared correctly.
Federal Program Information: Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (ALN #84.425E) and Institutional Portion (ALN #84.425F) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Annual Reporting for HEERF II and III - The HEERF Year 2 Annual Performance Report was required to be submitted to the Department of Education via the Annual Report Data Collection Tool by May 6, 2022 to cover the reporting period January 1, 2021 through December 31, 2021. The Department of Education collected information to provide the public with insight into how funds were used by institutions to support students and educators addressing the impact of COVID-19, and for helping to ensure accountability with respect to federal funds. Condition: Instances were identified where certain amounts reported within the HEERF Year 2 Annual Performance Report were inaccurate. Cause: Lack of administrative oversight with respect to amounts to be input within certain fields of the HEERF Year 2 Annual Performance Report. Effect: The College is not in compliance with HEERF reporting requirements. Questioned Costs: None. Context: The amount of Emergency Financial Aid Grants applied to satisfy student?s outstanding balance was double-counted for the period January 1, 2021 through December 31, 2021, which further resulted in the amount of grants disbursed to students through all HEERF funds to be overstated. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-010. Recommendation: We recommend the College enhance its procedures to ensure that the appropriate amounts are reported with each field of required HEERF reports. Views of Responsible Officials and Planned Corrective Actions: When preparing the HEERF Year 2 Annual Performance Report, a question was answered incorrectly due to a misinterpretation of what information the question was requesting. The College will put in place procedures to ensure future HEERF reports are prepared correctly.
Federal Program Information: Schedule of Expenditures of Federal Awards (Various ALN #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Reporting- The auditee must prepare a schedule of expenditures of Federal awards (the ?SEFA?) for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502 Basis for determining Federal awards expended. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For Research and Development (?R&D?), total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the passthrough entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the Assistance Listing number or other identifying number when the Assistance Listing information is not available. For a cluster of programs also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in 2 CFR 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule. (6) Include notes that describe that significant accounting policies used in preparing the schedule and note whether or not the auditee elected to use the 10% de minimis cost rate as covered in 2 CFR 200.414. Condition: The SEFA as prepared by management did not originally include one federal grant with federal expenditures to be reported within the 2022 SEFA. Cause: Lack of administrative oversight and insufficient internal controls with respect to preparation of the SEFA. Effect: The original draft SEFA was incomplete. Questioned Costs: None. Context: The original draft SEFA was incomplete. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-001. Recommendation: We recommend the College enhance its procedures and internal controls with respect to preparation and review of the SEFA. Views of Responsible Officials and Planned Corrective Actions: The grant included in the finding was received from a local government entity which did not communicate any reporting requirements associated with the grant. The College will be more vigilant in future years in assessing any grants received for inclusion on the SEFA.
Federal Program Information: Federal Perkins Loans (ALN #84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Perkins Loan Record Retention: An institution shall keep the original promissory notes and repayment schedules until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. (i) An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. (ii) If a promissory note was signed electronically, the institution must store it electronically and the promissory note must be retrievable in a coherent format. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied. 34 CFR 674.19(e)(4) Condition: Instance was identified where a Perkins master promissory note could not be located by the College. Cause: Lack of administrative oversight with respect to Perkins Loan record retention. Effect: The College is not in compliance with Perkins Loan record retention requirements. Questioned Costs: None. Context: For 1 of 25 students selected for testing, the College was unable to locate Perkins master promissory note. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College keep inventory of Perkins MPN records kept on campus. Views of Responsible Officials and Planned Corrective Actions: The College maintains all Perkins promissory notes in alphabetical order, in a dedicated filing cabinet, in a fireproof vault. This finding relates to a promissory note that was signed in 1987 and the College is not aware of what may have caused this Promissory note to be misplaced. No further action is planned by Management as the Perkins Loan Program expired on September 30, 2017 and no additional Perkins Loan disbursements were made by the College since the Program?s expiration.