Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Return of Title IV Funds: When a recipient of 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: The College did not prepare certain students’ return calculations properly.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: Below reportable threshold.
Context: For 3 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005.
Recommendation: We recommend the College enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The College agrees with this finding.
The Return to Title IV calculation was off due to the denominator of total days being incorrectly counted. The Director of Financial Aid will calculate the total days for each semester to be used for the calculation and publish them in the annual policy and procedure manual. The current financial aid procedures have been updated.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Federal Perkins Loan Program (ALN 84.038)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention: In accordance with 34 CFR 674.19(e), Institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense and National Direct Student Loans) made until the loans are satisfied.
Condition: The College was unable to provide certain borrowers’ records.
Cause: Administrative oversight.
Effect: The College is not in compliance with the Perkins Loan recordkeeping and record retention requirements.
Questioned Costs: None.
Context: For 3 of 40 borrowers tested, the College was unable to provide a copy of the borrower’s original paper promissory note or original paper MPN and repayment schedule.
Repeat Finding: This is a repeat of prior year Finding 2021-006.
Recommendation: We recommend the College enhance its policies and procedures to ensure that all Perkins Loan records are retained for the prescribed periods.
Views of Responsible Officials: The loans have been purchased by Birmingham-Southern College.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002.
Recommendation: We recommend the College enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the transmittal procedure to include reversing a federal aid posting in the event that it cannot be reconciled within ten days of its initial creation. The aid will be reposted once the issue is resolved and reported to COD on the day of positing. The current financial aid procedures have been updated.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported timely to NSLDS.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 35 campus level records tested, the College did not certify the student’s enrollment data within 60 days.
Error records from an Error/Acknowledgement file received during the fiscal year were not corrected within 10 days.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004.
Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are reported to NSLDS in a timely and accurate manner.
Views of Responsible Officials: The College has had significant staff turnover within the last year. The Office of Academic Records was operating with one staff member at that time. It is now operating at full staff capacity and will be better able to follow up on reporting errors to make necessary corrections.
The findings for students with incorrect NSLDS status reports were corrected in March 2023.
The College is working on a better, more comprehensive withdrawal policy in the next academic year which will assist in identifying non-returning students at an earlier date to better fit the 60-day allotted time frame. In addition, the Office of Academic Records plans to alter enrollment reporting schedules to better fit our academic calendar to meet the 60-day time frame requirement. This change should capture our Fall and Winter graduates within the allotted time requirement.
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Return of Title IV Funds: When a recipient of 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: The College did not prepare certain students’ return calculations properly.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: Below reportable threshold.
Context: For 3 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005.
Recommendation: We recommend the College enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The College agrees with this finding.
The Return to Title IV calculation was off due to the denominator of total days being incorrectly counted. The Director of Financial Aid will calculate the total days for each semester to be used for the calculation and publish them in the annual policy and procedure manual. The current financial aid procedures have been updated.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002.
Recommendation: We recommend the College enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the transmittal procedure to include reversing a federal aid posting in the event that it cannot be reconciled within ten days of its initial creation. The aid will be reposted once the issue is resolved and reported to COD on the day of positing. The current financial aid procedures have been updated.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported timely to NSLDS.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 35 campus level records tested, the College did not certify the student’s enrollment data within 60 days.
Error records from an Error/Acknowledgement file received during the fiscal year were not corrected within 10 days.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004.
Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are reported to NSLDS in a timely and accurate manner.
Views of Responsible Officials: The College has had significant staff turnover within the last year. The Office of Academic Records was operating with one staff member at that time. It is now operating at full staff capacity and will be better able to follow up on reporting errors to make necessary corrections.
The findings for students with incorrect NSLDS status reports were corrected in March 2023.
The College is working on a better, more comprehensive withdrawal policy in the next academic year which will assist in identifying non-returning students at an earlier date to better fit the 60-day allotted time frame. In addition, the Office of Academic Records plans to alter enrollment reporting schedules to better fit our academic calendar to meet the 60-day time frame requirement. This change should capture our Fall and Winter graduates within the allotted time requirement.
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Return of Title IV Funds: When a recipient of 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: The College did not prepare certain students’ return calculations properly.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: Below reportable threshold.
Context: For 3 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005.
Recommendation: We recommend the College enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The College agrees with this finding.
The Return to Title IV calculation was off due to the denominator of total days being incorrectly counted. The Director of Financial Aid will calculate the total days for each semester to be used for the calculation and publish them in the annual policy and procedure manual. The current financial aid procedures have been updated.
Federal Program Information: Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the 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: Certain parent PLUS loan borrowers were not notified of loan disbursements to their dependent’s account.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with loan notification requirements.
Questioned Costs: None.
Context: For 5 of 40 Direct Loan disbursements tested, the College was unable to provide documentation showing that a notification was sent to the parent borrower.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials: The College agrees with this finding.
The Financial Aid Office has updated the procedure to clearly specify a separate notice to all parents who borrow using the Parent Plus. Each borrowing parent will receive a notification mailed to the address used on the Parent Plus application. The current financial aid procedures were updated in spring of 2022 and carried out successfully.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Education Stabilization Fund (ALN 84.425E, ALN 84.425F)
Criteria or Specific Requirement: The Certification and Agreements for the CRRSAA and ARP (a)(1) and (a)(4) funds provide that each institution applying for HEERF funds must promptly and timely provide a detailed accounting of the use and expenditure of the funds in such manner and with such frequency as the Secretary may require. Each HEERF participating institution must post certain information on the institution’s primary website as soon as possible, but no later than 30 days after the publication of the May 13, 2021 notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30).
Condition: The College did not publicly post certain Student Aid Portion reports for calendar quarters ended during fiscal year 2022. Certain reports were also not submitted within the required timeframe.
Additionally, quarterly reporting of lost revenue did not match the amount claimed/drawn in G5. While the College had sufficient lost revenue to substantiate the amount drawn, it was further noted that the College’s lost revenue determination was not in line with prescribed methods.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with the HEERF quarterly reporting requirements.
Questioned Costs: None.
Context: Student Aid Portion reports for the calendar quarters ended September 30, 2021 and June 30, 2022 were not posted to the College’s website.
1 of 4 Quarterly Budget and Expenditure Reports submitted during the fiscal year were not submitted within 10 days of quarter-end.
The 2021 Annual Performance Report was not submitted by the May 6, 2022 deadline.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-007.
Recommendation: We recommend the College enhance its procedures and internal controls to ensure that HEERF data is reported in a timely and accurate manner.
Views of Responsible Officials: The College experienced some staff changes in the financial aid and accounting offices. The College will update the required reporting on its website at https://www.bsc.edu/emergencyrelieffund.html.
Federal Program Information: Education Stabilization Fund (ALN 84.425E)
Criteria or Specific Requirement: Institutions must receive affirmative written consent before providing an emergency financial aid grant to a student’s
account.
Condition: For certain emergency grant recipients, the College was unable to provide documentation showing that the students consented to the College crediting grant funds to their student accounts.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College was not in compliance with federal guidelines over making emergency financial aid grants to students.
Questioned Costs: None.
Context: For 5 of 25 emergency grants tested, the College was unable to provide the necessary documentation to ascertain whether affirmative written consent was obtained.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures over awarding and disbursing financial aid to ensure adherence to all federal guidelines.
Views of Responsible Officials: The offering of HEERF grant funding was emailed to all students. Students would opt in or opt out which would generate a response email. The acceptance responses were sent to two staff e-mails in the communication department as well as the previous Financial Aid Director. Unfortunately, all three staff members have left BSC and their email accounts have been closed. Beginning the spring of 2022, all HEERF acceptance emails were saved in an institutional shared drive to ensure appropriate record keeping.
Federal Program Information: Education Stabilization Fund (ALN 84.425E, ALN 84.425F)
Criteria or Specific Requirement: The Certification and Agreements for the CRRSAA and ARP (a)(1) and (a)(4) funds provide that each institution applying for HEERF funds must promptly and timely provide a detailed accounting of the use and expenditure of the funds in such manner and with such frequency as the Secretary may require. Each HEERF participating institution must post certain information on the institution’s primary website as soon as possible, but no later than 30 days after the publication of the May 13, 2021 notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30).
Condition: The College did not publicly post certain Student Aid Portion reports for calendar quarters ended during fiscal year 2022. Certain reports were also not submitted within the required timeframe.
Additionally, quarterly reporting of lost revenue did not match the amount claimed/drawn in G5. While the College had sufficient lost revenue to substantiate the amount drawn, it was further noted that the College’s lost revenue determination was not in line with prescribed methods.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with the HEERF quarterly reporting requirements.
Questioned Costs: None.
Context: Student Aid Portion reports for the calendar quarters ended September 30, 2021 and June 30, 2022 were not posted to the College’s website.
1 of 4 Quarterly Budget and Expenditure Reports submitted during the fiscal year were not submitted within 10 days of quarter-end.
The 2021 Annual Performance Report was not submitted by the May 6, 2022 deadline.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-007.
Recommendation: We recommend the College enhance its procedures and internal controls to ensure that HEERF data is reported in a timely and accurate manner.
Views of Responsible Officials: The College experienced some staff changes in the financial aid and accounting offices. The College will update the required reporting on its website at https://www.bsc.edu/emergencyrelieffund.html.
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Return of Title IV Funds: When a recipient of 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: The College did not prepare certain students’ return calculations properly.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: Below reportable threshold.
Context: For 3 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005.
Recommendation: We recommend the College enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The College agrees with this finding.
The Return to Title IV calculation was off due to the denominator of total days being incorrectly counted. The Director of Financial Aid will calculate the total days for each semester to be used for the calculation and publish them in the annual policy and procedure manual. The current financial aid procedures have been updated.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Federal Perkins Loan Program (ALN 84.038)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention: In accordance with 34 CFR 674.19(e), Institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense and National Direct Student Loans) made until the loans are satisfied.
Condition: The College was unable to provide certain borrowers’ records.
Cause: Administrative oversight.
Effect: The College is not in compliance with the Perkins Loan recordkeeping and record retention requirements.
Questioned Costs: None.
Context: For 3 of 40 borrowers tested, the College was unable to provide a copy of the borrower’s original paper promissory note or original paper MPN and repayment schedule.
Repeat Finding: This is a repeat of prior year Finding 2021-006.
Recommendation: We recommend the College enhance its policies and procedures to ensure that all Perkins Loan records are retained for the prescribed periods.
Views of Responsible Officials: The loans have been purchased by Birmingham-Southern College.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002.
Recommendation: We recommend the College enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the transmittal procedure to include reversing a federal aid posting in the event that it cannot be reconciled within ten days of its initial creation. The aid will be reposted once the issue is resolved and reported to COD on the day of positing. The current financial aid procedures have been updated.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported timely to NSLDS.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 35 campus level records tested, the College did not certify the student’s enrollment data within 60 days.
Error records from an Error/Acknowledgement file received during the fiscal year were not corrected within 10 days.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004.
Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are reported to NSLDS in a timely and accurate manner.
Views of Responsible Officials: The College has had significant staff turnover within the last year. The Office of Academic Records was operating with one staff member at that time. It is now operating at full staff capacity and will be better able to follow up on reporting errors to make necessary corrections.
The findings for students with incorrect NSLDS status reports were corrected in March 2023.
The College is working on a better, more comprehensive withdrawal policy in the next academic year which will assist in identifying non-returning students at an earlier date to better fit the 60-day allotted time frame. In addition, the Office of Academic Records plans to alter enrollment reporting schedules to better fit our academic calendar to meet the 60-day time frame requirement. This change should capture our Fall and Winter graduates within the allotted time requirement.
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Return of Title IV Funds: When a recipient of 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: The College did not prepare certain students’ return calculations properly.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: Below reportable threshold.
Context: For 3 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005.
Recommendation: We recommend the College enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The College agrees with this finding.
The Return to Title IV calculation was off due to the denominator of total days being incorrectly counted. The Director of Financial Aid will calculate the total days for each semester to be used for the calculation and publish them in the annual policy and procedure manual. The current financial aid procedures have been updated.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: L. Reporting – Common Origination and Disbursement System Reporting: Institutions submit Federal Direct Loan Program, Federal Pell Grant Program, and TEACH Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. The U.S. Department of Education (the “ED”) processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.
Condition: Certain student disbursements were not reported to COD within 15 calendar days as required.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the COD reporting requirements.
Questioned Costs: None.
Context: For 1 of 40 Direct Loan disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
For 2 of 25 Pell disbursement records tested, the disbursement was not reported to COD within 15 calendar days.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-002.
Recommendation: We recommend the College enhance its procedures over disbursement record submissions to ensure timely and accurate reporting to COD.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the transmittal procedure to include reversing a federal aid posting in the event that it cannot be reconciled within ten days of its initial creation. The aid will be reposted once the issue is resolved and reported to COD on the day of positing. The current financial aid procedures have been updated.
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: Campus Level: Certain students’ enrollment status changes were not reported timely to NSLDS.
Additionally, error records were not corrected within the required timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with the enrollment reporting requirements.
Questioned Costs: None.
Context: For 2 of 35 campus level records tested, the College did not certify the student’s enrollment data within 60 days.
Error records from an Error/Acknowledgement file received during the fiscal year were not corrected within 10 days.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-004.
Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are reported to NSLDS in a timely and accurate manner.
Views of Responsible Officials: The College has had significant staff turnover within the last year. The Office of Academic Records was operating with one staff member at that time. It is now operating at full staff capacity and will be better able to follow up on reporting errors to make necessary corrections.
The findings for students with incorrect NSLDS status reports were corrected in March 2023.
The College is working on a better, more comprehensive withdrawal policy in the next academic year which will assist in identifying non-returning students at an earlier date to better fit the 60-day allotted time frame. In addition, the Office of Academic Records plans to alter enrollment reporting schedules to better fit our academic calendar to meet the 60-day time frame requirement. This change should capture our Fall and Winter graduates within the allotted time requirement.
Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Return of Title IV Funds: When a recipient of 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. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn.
Condition: The College did not prepare certain students’ return calculations properly.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: Over or underpayment of Title IV funds.
Questioned Costs: Below reportable threshold.
Context: For 3 of 4 students tested, the amounts to return were not calculated in accordance with the requirements.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2021-005.
Recommendation: We recommend the College enhance its procedures and internal controls over the preparation and review of R2T4 calculations to ensure that return amounts are accurately determined.
Views of Responsible Officials: The College agrees with this finding.
The Return to Title IV calculation was off due to the denominator of total days being incorrectly counted. The Director of Financial Aid will calculate the total days for each semester to be used for the calculation and publish them in the annual policy and procedure manual. The current financial aid procedures have been updated.
Federal Program Information: Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement: N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the 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: Certain parent PLUS loan borrowers were not notified of loan disbursements to their dependent’s account.
Cause: Administrative oversight.
Effect or Potential Effect: The College was not in compliance with loan notification requirements.
Questioned Costs: None.
Context: For 5 of 40 Direct Loan disbursements tested, the College was unable to provide documentation showing that a notification was sent to the parent borrower.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures over loan notifications to ensure timely and accurate notification to borrowers.
Views of Responsible Officials: The College agrees with this finding.
The Financial Aid Office has updated the procedure to clearly specify a separate notice to all parents who borrow using the Parent Plus. Each borrowing parent will receive a notification mailed to the address used on the Parent Plus application. The current financial aid procedures were updated in spring of 2022 and carried out successfully.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (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 (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Test and Provisions - Gramm-Leach-Bliley Act: In order to develop, implement, and maintain its information security program, the institution shall identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such risk assessment should include consideration of risks in each relevant area of the institution’s operations, including: (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures (16 CFR § 314.4).
Condition: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with required federal guidelines.
Questioned Costs: None.
Context: The College was unable to provide documentation supporting the completion of an appropriate risk assessment as required by the Gramm-Leach-Bliley Act.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls surrounding the completion of a risk assessment to ensure compliance with the Gramm-Leach Bliley Act.
Views of Responsible Officials: The College will perform a risk assessment and document safeguards for identified risks.
Federal Program Information: Education Stabilization Fund (ALN 84.425E, ALN 84.425F)
Criteria or Specific Requirement: The Certification and Agreements for the CRRSAA and ARP (a)(1) and (a)(4) funds provide that each institution applying for HEERF funds must promptly and timely provide a detailed accounting of the use and expenditure of the funds in such manner and with such frequency as the Secretary may require. Each HEERF participating institution must post certain information on the institution’s primary website as soon as possible, but no later than 30 days after the publication of the May 13, 2021 notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30).
Condition: The College did not publicly post certain Student Aid Portion reports for calendar quarters ended during fiscal year 2022. Certain reports were also not submitted within the required timeframe.
Additionally, quarterly reporting of lost revenue did not match the amount claimed/drawn in G5. While the College had sufficient lost revenue to substantiate the amount drawn, it was further noted that the College’s lost revenue determination was not in line with prescribed methods.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with the HEERF quarterly reporting requirements.
Questioned Costs: None.
Context: Student Aid Portion reports for the calendar quarters ended September 30, 2021 and June 30, 2022 were not posted to the College’s website.
1 of 4 Quarterly Budget and Expenditure Reports submitted during the fiscal year were not submitted within 10 days of quarter-end.
The 2021 Annual Performance Report was not submitted by the May 6, 2022 deadline.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-007.
Recommendation: We recommend the College enhance its procedures and internal controls to ensure that HEERF data is reported in a timely and accurate manner.
Views of Responsible Officials: The College experienced some staff changes in the financial aid and accounting offices. The College will update the required reporting on its website at https://www.bsc.edu/emergencyrelieffund.html.
Federal Program Information: Education Stabilization Fund (ALN 84.425E)
Criteria or Specific Requirement: Institutions must receive affirmative written consent before providing an emergency financial aid grant to a student’s
account.
Condition: For certain emergency grant recipients, the College was unable to provide documentation showing that the students consented to the College crediting grant funds to their student accounts.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College was not in compliance with federal guidelines over making emergency financial aid grants to students.
Questioned Costs: None.
Context: For 5 of 25 emergency grants tested, the College was unable to provide the necessary documentation to ascertain whether affirmative written consent was obtained.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures over awarding and disbursing financial aid to ensure adherence to all federal guidelines.
Views of Responsible Officials: The offering of HEERF grant funding was emailed to all students. Students would opt in or opt out which would generate a response email. The acceptance responses were sent to two staff e-mails in the communication department as well as the previous Financial Aid Director. Unfortunately, all three staff members have left BSC and their email accounts have been closed. Beginning the spring of 2022, all HEERF acceptance emails were saved in an institutional shared drive to ensure appropriate record keeping.
Federal Program Information: Education Stabilization Fund (ALN 84.425E, ALN 84.425F)
Criteria or Specific Requirement: The Certification and Agreements for the CRRSAA and ARP (a)(1) and (a)(4) funds provide that each institution applying for HEERF funds must promptly and timely provide a detailed accounting of the use and expenditure of the funds in such manner and with such frequency as the Secretary may require. Each HEERF participating institution must post certain information on the institution’s primary website as soon as possible, but no later than 30 days after the publication of the May 13, 2021 notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30).
Condition: The College did not publicly post certain Student Aid Portion reports for calendar quarters ended during fiscal year 2022. Certain reports were also not submitted within the required timeframe.
Additionally, quarterly reporting of lost revenue did not match the amount claimed/drawn in G5. While the College had sufficient lost revenue to substantiate the amount drawn, it was further noted that the College’s lost revenue determination was not in line with prescribed methods.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College is not in compliance with the HEERF quarterly reporting requirements.
Questioned Costs: None.
Context: Student Aid Portion reports for the calendar quarters ended September 30, 2021 and June 30, 2022 were not posted to the College’s website.
1 of 4 Quarterly Budget and Expenditure Reports submitted during the fiscal year were not submitted within 10 days of quarter-end.
The 2021 Annual Performance Report was not submitted by the May 6, 2022 deadline.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-007.
Recommendation: We recommend the College enhance its procedures and internal controls to ensure that HEERF data is reported in a timely and accurate manner.
Views of Responsible Officials: The College experienced some staff changes in the financial aid and accounting offices. The College will update the required reporting on its website at https://www.bsc.edu/emergencyrelieffund.html.