Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work-Study and 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-006
Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws, cr expresses notification to withdraw, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)).
Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds.
Questioned Costs - $3,713
Identification of How Questioned Costs Were Computed - Procedures identified a population of two students that met the requirements to have a calculation performed. Of those students, it was determined one student’s aid should have been returned and the actual amount calculated is reported as questioned costs.
Context - Of the four students identified that received Title IV funding and met the definition of an official or unofficial withdrawal during the period, two students did not have a calculation documented by the Seminary. Although documentaton was not maintained, one student had the full loan returned timely without calculating the earned portion for the Seminary, while the other students award was not calculated or returned to the Department of Education in accordance with the regulations.
Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student’s individual facts and circumstances, including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal.
Views of Responsible Officials and Planned Corrective Actions - The financial aid director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The financial aid director created a listing to track all student withdrawals (including details of withdrawal). The registrar sends an email to the financial aid director notifying when a student has withdrawn from the institution, which gets entered onto the list. The financial aid director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and, if necessary, funds are returned to the Department of Education.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loan
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 688.34 for applying and monitoring satisfactory academic progress for determining eligibility of students receiving Title IV aid. Institutions are also required to have a policy that provides notification of the results of an evaluation that impacts the students eligibility for Title IV funds.
Condition - The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP).
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 19 students tested, 1 student was identified who did not meet all of the Seminary's requirements under its satisfactory academic progress policy and who should have been placed on financial aid warning prior to the disbursement of aid; however, this did not result in an ineligible disbursement, as this was the initial semester that the student fell below the requirements included in the Seminary's policy.
Cause and Effect - The Seminary's processes and controls did not identity that a student was not meeting the satisfactory academic progress policy, which could lead to the disbursement of funds to ineligible students.
Recommendation - We recommend the Seminary review its procedures and controls to ensure that students who are not in compliance with the Seminar's satisfactory academic progress policies are identified, notified, and further monitored.
Views of Responsible Officials and Corrective Action Plan - Satisfactory academic progress is now being monitored more carefully. The satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the registrar and financial aid director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the financial aid director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar Financial Aid account.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-003
Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (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; 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 in accordance with 34 CFR 668.165.
Condition - Of the 19 students who received disbursements selected for testing, the Seminary did not notify any of the students or parents, as applicable, that received direct federal loans within the required 30 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, our testing identified that none of the 19 students who received federal direct loans were notified at all.
Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year.
Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program.
Views of Responsible Officials and Planned Corrective Actions - Directly after a students’ direct loan is disbursed, the financial aid director manually sends the loan disbursement notification email to the student (through the Jenzabar Financial Aid system), which specifies the amount that they borrowed for the term and the right to cancel the loan within 14 days by emailing the financial aid office. This email is recorded in the Jenzabar Financial Aid system. The financial aid director also created a spreadsheet to track direct loan disbursements and notifications each term.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work-Study and 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-006
Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws, cr expresses notification to withdraw, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)).
Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds.
Questioned Costs - $3,713
Identification of How Questioned Costs Were Computed - Procedures identified a population of two students that met the requirements to have a calculation performed. Of those students, it was determined one student’s aid should have been returned and the actual amount calculated is reported as questioned costs.
Context - Of the four students identified that received Title IV funding and met the definition of an official or unofficial withdrawal during the period, two students did not have a calculation documented by the Seminary. Although documentaton was not maintained, one student had the full loan returned timely without calculating the earned portion for the Seminary, while the other students award was not calculated or returned to the Department of Education in accordance with the regulations.
Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student’s individual facts and circumstances, including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal.
Views of Responsible Officials and Planned Corrective Actions - The financial aid director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The financial aid director created a listing to track all student withdrawals (including details of withdrawal). The registrar sends an email to the financial aid director notifying when a student has withdrawn from the institution, which gets entered onto the list. The financial aid director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and, if necessary, funds are returned to the Department of Education.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-007
Criteria - In accordance With 34 CFR § 668.164-(h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, audit testing identified 8 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance.
Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts.
Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students.
Views of Responsible Officials and Planned Corrective Actions - Beginning with the fall 2023 term, Title IV credit balances are no longer held past the 14 days with authorization from the student. The financial aid director implemented a new policy where students cannot request that these funds are retained beyond 14 days. There is a shared list where the business office enters the date that the student's credit balance was released to verify that process happens within 14 days.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-002
Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9).
Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place.
Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time.
Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs.
Views of Responsible Officials and Planned Corrective Actions - Within one to two weeks of each month's end, the financial aid director requests a report from COD (U.S. Department of Education Common Origination & Disbursement) for direct loans disbursed that month. That report is retrieved through EDConnect and reviewed. The financial aid director generates a report from Jenzabar Financial Aid system of direct loans disbursed for that month. The financial aid director also retrieves a report of direct loans applied to students' accounts for that month from the business office senior accountant. These three reports are then compared and reconciled for each month.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - The Seminary has 60 days from the date the Seminary determines an enrollment status change to report to NSLDS. The enrollment reporting must be updated for changes in the data elements for the campus record and the program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309).
Condition - Of the nine students selected for enrollment reporting testing, the Seminary did not properly update student enrollment information for one student in a timely manner.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of nine students, our testing identified one that was not properly reported as graduated when the Seminary had determined they were.
Cause and Effect - The Seminary did not have formal procedures and controls in place to document students that need to be added back to the roster to report their graduated status. The lack of documentation of withdrawn students awaiting graduation led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should consider implementing a process to submit a final enrollment file upon completion of processing graduates and reviewing procedures to verify that the information uploaded and reported is complete, accurate, and timely.
Views of Responsible Officials and Planned Corrective Actions - Students who finish their degree in December are reported as “withdrawn,” as there is no option to confer in December (institutional policy). The student status is updated to "graduated” and reported to Clearinghouse in May when students are conferred.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loan
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 688.34 for applying and monitoring satisfactory academic progress for determining eligibility of students receiving Title IV aid. Institutions are also required to have a policy that provides notification of the results of an evaluation that impacts the students eligibility for Title IV funds.
Condition - The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP).
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 19 students tested, 1 student was identified who did not meet all of the Seminary's requirements under its satisfactory academic progress policy and who should have been placed on financial aid warning prior to the disbursement of aid; however, this did not result in an ineligible disbursement, as this was the initial semester that the student fell below the requirements included in the Seminary's policy.
Cause and Effect - The Seminary's processes and controls did not identity that a student was not meeting the satisfactory academic progress policy, which could lead to the disbursement of funds to ineligible students.
Recommendation - We recommend the Seminary review its procedures and controls to ensure that students who are not in compliance with the Seminar's satisfactory academic progress policies are identified, notified, and further monitored.
Views of Responsible Officials and Corrective Action Plan - Satisfactory academic progress is now being monitored more carefully. The satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the registrar and financial aid director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the financial aid director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar Financial Aid account.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-003
Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (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; 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 in accordance with 34 CFR 668.165.
Condition - Of the 19 students who received disbursements selected for testing, the Seminary did not notify any of the students or parents, as applicable, that received direct federal loans within the required 30 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, our testing identified that none of the 19 students who received federal direct loans were notified at all.
Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year.
Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program.
Views of Responsible Officials and Planned Corrective Actions - Directly after a students’ direct loan is disbursed, the financial aid director manually sends the loan disbursement notification email to the student (through the Jenzabar Financial Aid system), which specifies the amount that they borrowed for the term and the right to cancel the loan within 14 days by emailing the financial aid office. This email is recorded in the Jenzabar Financial Aid system. The financial aid director also created a spreadsheet to track direct loan disbursements and notifications each term.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work-Study and 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-006
Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws, cr expresses notification to withdraw, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)).
Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds.
Questioned Costs - $3,713
Identification of How Questioned Costs Were Computed - Procedures identified a population of two students that met the requirements to have a calculation performed. Of those students, it was determined one student’s aid should have been returned and the actual amount calculated is reported as questioned costs.
Context - Of the four students identified that received Title IV funding and met the definition of an official or unofficial withdrawal during the period, two students did not have a calculation documented by the Seminary. Although documentaton was not maintained, one student had the full loan returned timely without calculating the earned portion for the Seminary, while the other students award was not calculated or returned to the Department of Education in accordance with the regulations.
Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student’s individual facts and circumstances, including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal.
Views of Responsible Officials and Planned Corrective Actions - The financial aid director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The financial aid director created a listing to track all student withdrawals (including details of withdrawal). The registrar sends an email to the financial aid director notifying when a student has withdrawn from the institution, which gets entered onto the list. The financial aid director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and, if necessary, funds are returned to the Department of Education.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-007
Criteria - In accordance With 34 CFR § 668.164-(h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, audit testing identified 8 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance.
Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts.
Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students.
Views of Responsible Officials and Planned Corrective Actions - Beginning with the fall 2023 term, Title IV credit balances are no longer held past the 14 days with authorization from the student. The financial aid director implemented a new policy where students cannot request that these funds are retained beyond 14 days. There is a shared list where the business office enters the date that the student's credit balance was released to verify that process happens within 14 days.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-002
Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9).
Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place.
Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time.
Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs.
Views of Responsible Officials and Planned Corrective Actions - Within one to two weeks of each month's end, the financial aid director requests a report from COD (U.S. Department of Education Common Origination & Disbursement) for direct loans disbursed that month. That report is retrieved through EDConnect and reviewed. The financial aid director generates a report from Jenzabar Financial Aid system of direct loans disbursed for that month. The financial aid director also retrieves a report of direct loans applied to students' accounts for that month from the business office senior accountant. These three reports are then compared and reconciled for each month.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - The Seminary has 60 days from the date the Seminary determines an enrollment status change to report to NSLDS. The enrollment reporting must be updated for changes in the data elements for the campus record and the program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309).
Condition - Of the nine students selected for enrollment reporting testing, the Seminary did not properly update student enrollment information for one student in a timely manner.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of nine students, our testing identified one that was not properly reported as graduated when the Seminary had determined they were.
Cause and Effect - The Seminary did not have formal procedures and controls in place to document students that need to be added back to the roster to report their graduated status. The lack of documentation of withdrawn students awaiting graduation led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should consider implementing a process to submit a final enrollment file upon completion of processing graduates and reviewing procedures to verify that the information uploaded and reported is complete, accurate, and timely.
Views of Responsible Officials and Planned Corrective Actions - Students who finish their degree in December are reported as “withdrawn,” as there is no option to confer in December (institutional policy). The student status is updated to "graduated” and reported to Clearinghouse in May when students are conferred.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loan
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 688.34 for applying and monitoring satisfactory academic progress for determining eligibility of students receiving Title IV aid. Institutions are also required to have a policy that provides notification of the results of an evaluation that impacts the students eligibility for Title IV funds.
Condition - The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP).
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 19 students tested, 1 student was identified who did not meet all of the Seminary's requirements under its satisfactory academic progress policy and who should have been placed on financial aid warning prior to the disbursement of aid; however, this did not result in an ineligible disbursement, as this was the initial semester that the student fell below the requirements included in the Seminary's policy.
Cause and Effect - The Seminary's processes and controls did not identity that a student was not meeting the satisfactory academic progress policy, which could lead to the disbursement of funds to ineligible students.
Recommendation - We recommend the Seminary review its procedures and controls to ensure that students who are not in compliance with the Seminar's satisfactory academic progress policies are identified, notified, and further monitored.
Views of Responsible Officials and Corrective Action Plan - Satisfactory academic progress is now being monitored more carefully. The satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the registrar and financial aid director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the financial aid director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar Financial Aid account.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work-Study and 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-006
Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws, cr expresses notification to withdraw, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)).
Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds.
Questioned Costs - $3,713
Identification of How Questioned Costs Were Computed - Procedures identified a population of two students that met the requirements to have a calculation performed. Of those students, it was determined one student’s aid should have been returned and the actual amount calculated is reported as questioned costs.
Context - Of the four students identified that received Title IV funding and met the definition of an official or unofficial withdrawal during the period, two students did not have a calculation documented by the Seminary. Although documentaton was not maintained, one student had the full loan returned timely without calculating the earned portion for the Seminary, while the other students award was not calculated or returned to the Department of Education in accordance with the regulations.
Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student’s individual facts and circumstances, including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal.
Views of Responsible Officials and Planned Corrective Actions - The financial aid director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The financial aid director created a listing to track all student withdrawals (including details of withdrawal). The registrar sends an email to the financial aid director notifying when a student has withdrawn from the institution, which gets entered onto the list. The financial aid director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and, if necessary, funds are returned to the Department of Education.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loan
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 688.34 for applying and monitoring satisfactory academic progress for determining eligibility of students receiving Title IV aid. Institutions are also required to have a policy that provides notification of the results of an evaluation that impacts the students eligibility for Title IV funds.
Condition - The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP).
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 19 students tested, 1 student was identified who did not meet all of the Seminary's requirements under its satisfactory academic progress policy and who should have been placed on financial aid warning prior to the disbursement of aid; however, this did not result in an ineligible disbursement, as this was the initial semester that the student fell below the requirements included in the Seminary's policy.
Cause and Effect - The Seminary's processes and controls did not identity that a student was not meeting the satisfactory academic progress policy, which could lead to the disbursement of funds to ineligible students.
Recommendation - We recommend the Seminary review its procedures and controls to ensure that students who are not in compliance with the Seminar's satisfactory academic progress policies are identified, notified, and further monitored.
Views of Responsible Officials and Corrective Action Plan - Satisfactory academic progress is now being monitored more carefully. The satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the registrar and financial aid director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the financial aid director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar Financial Aid account.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-003
Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (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; 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 in accordance with 34 CFR 668.165.
Condition - Of the 19 students who received disbursements selected for testing, the Seminary did not notify any of the students or parents, as applicable, that received direct federal loans within the required 30 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, our testing identified that none of the 19 students who received federal direct loans were notified at all.
Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year.
Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program.
Views of Responsible Officials and Planned Corrective Actions - Directly after a students’ direct loan is disbursed, the financial aid director manually sends the loan disbursement notification email to the student (through the Jenzabar Financial Aid system), which specifies the amount that they borrowed for the term and the right to cancel the loan within 14 days by emailing the financial aid office. This email is recorded in the Jenzabar Financial Aid system. The financial aid director also created a spreadsheet to track direct loan disbursements and notifications each term.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work-Study and 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-006
Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws, cr expresses notification to withdraw, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)).
Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds.
Questioned Costs - $3,713
Identification of How Questioned Costs Were Computed - Procedures identified a population of two students that met the requirements to have a calculation performed. Of those students, it was determined one student’s aid should have been returned and the actual amount calculated is reported as questioned costs.
Context - Of the four students identified that received Title IV funding and met the definition of an official or unofficial withdrawal during the period, two students did not have a calculation documented by the Seminary. Although documentaton was not maintained, one student had the full loan returned timely without calculating the earned portion for the Seminary, while the other students award was not calculated or returned to the Department of Education in accordance with the regulations.
Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student’s individual facts and circumstances, including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal.
Views of Responsible Officials and Planned Corrective Actions - The financial aid director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The financial aid director created a listing to track all student withdrawals (including details of withdrawal). The registrar sends an email to the financial aid director notifying when a student has withdrawn from the institution, which gets entered onto the list. The financial aid director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and, if necessary, funds are returned to the Department of Education.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-007
Criteria - In accordance With 34 CFR § 668.164-(h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, audit testing identified 8 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance.
Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts.
Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students.
Views of Responsible Officials and Planned Corrective Actions - Beginning with the fall 2023 term, Title IV credit balances are no longer held past the 14 days with authorization from the student. The financial aid director implemented a new policy where students cannot request that these funds are retained beyond 14 days. There is a shared list where the business office enters the date that the student's credit balance was released to verify that process happens within 14 days.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-002
Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9).
Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place.
Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time.
Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs.
Views of Responsible Officials and Planned Corrective Actions - Within one to two weeks of each month's end, the financial aid director requests a report from COD (U.S. Department of Education Common Origination & Disbursement) for direct loans disbursed that month. That report is retrieved through EDConnect and reviewed. The financial aid director generates a report from Jenzabar Financial Aid system of direct loans disbursed for that month. The financial aid director also retrieves a report of direct loans applied to students' accounts for that month from the business office senior accountant. These three reports are then compared and reconciled for each month.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - The Seminary has 60 days from the date the Seminary determines an enrollment status change to report to NSLDS. The enrollment reporting must be updated for changes in the data elements for the campus record and the program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309).
Condition - Of the nine students selected for enrollment reporting testing, the Seminary did not properly update student enrollment information for one student in a timely manner.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of nine students, our testing identified one that was not properly reported as graduated when the Seminary had determined they were.
Cause and Effect - The Seminary did not have formal procedures and controls in place to document students that need to be added back to the roster to report their graduated status. The lack of documentation of withdrawn students awaiting graduation led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should consider implementing a process to submit a final enrollment file upon completion of processing graduates and reviewing procedures to verify that the information uploaded and reported is complete, accurate, and timely.
Views of Responsible Officials and Planned Corrective Actions - Students who finish their degree in December are reported as “withdrawn,” as there is no option to confer in December (institutional policy). The student status is updated to "graduated” and reported to Clearinghouse in May when students are conferred.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loan
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 688.34 for applying and monitoring satisfactory academic progress for determining eligibility of students receiving Title IV aid. Institutions are also required to have a policy that provides notification of the results of an evaluation that impacts the students eligibility for Title IV funds.
Condition - The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP).
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 19 students tested, 1 student was identified who did not meet all of the Seminary's requirements under its satisfactory academic progress policy and who should have been placed on financial aid warning prior to the disbursement of aid; however, this did not result in an ineligible disbursement, as this was the initial semester that the student fell below the requirements included in the Seminary's policy.
Cause and Effect - The Seminary's processes and controls did not identity that a student was not meeting the satisfactory academic progress policy, which could lead to the disbursement of funds to ineligible students.
Recommendation - We recommend the Seminary review its procedures and controls to ensure that students who are not in compliance with the Seminar's satisfactory academic progress policies are identified, notified, and further monitored.
Views of Responsible Officials and Corrective Action Plan - Satisfactory academic progress is now being monitored more carefully. The satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the registrar and financial aid director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the financial aid director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar Financial Aid account.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-003
Criteria - The Seminary must notify the student or parent in writing of the following related to the student's direct loan: (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; 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 in accordance with 34 CFR 668.165.
Condition - Of the 19 students who received disbursements selected for testing, the Seminary did not notify any of the students or parents, as applicable, that received direct federal loans within the required 30 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, our testing identified that none of the 19 students who received federal direct loans were notified at all.
Cause and Effect - The Seminary did not have formal procedures and controls in place to notify borrowers of their amounts, rights, and procedures related to the disbursement of federal direct loans for the full year.
Recommendation - We recommend the Seminary maintain a procedure and control in place to ensure that, upon each disbursement of direct loans, the Seminary notifies the borrower of the required elements in accordance with the loan program.
Views of Responsible Officials and Planned Corrective Actions - Directly after a students’ direct loan is disbursed, the financial aid director manually sends the loan disbursement notification email to the student (through the Jenzabar Financial Aid system), which specifies the amount that they borrowed for the term and the right to cancel the loan within 14 days by emailing the financial aid office. This email is recorded in the Jenzabar Financial Aid system. The financial aid director also created a spreadsheet to track direct loan disbursements and notifications each term.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work-Study and 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-006
Criteria - The Seminary has 45 days from the date the college determines a student's withdrawal date to calculate a return of Title IV funds for the student and return the funds. Withdrawal dates are defined as the time when the student officially withdraws, cr expresses notification to withdraw, or if the student does not officially withdraw, the date the Seminary determines the student is no longer in attendance (34 CFR Section 668.22(j)(1)).
Condition - The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds.
Questioned Costs - $3,713
Identification of How Questioned Costs Were Computed - Procedures identified a population of two students that met the requirements to have a calculation performed. Of those students, it was determined one student’s aid should have been returned and the actual amount calculated is reported as questioned costs.
Context - Of the four students identified that received Title IV funding and met the definition of an official or unofficial withdrawal during the period, two students did not have a calculation documented by the Seminary. Although documentaton was not maintained, one student had the full loan returned timely without calculating the earned portion for the Seminary, while the other students award was not calculated or returned to the Department of Education in accordance with the regulations.
Cause and Effect - The Seminary did not have proper controls in place to identity and document students who have withdrawn from the Seminary. The lack of documentation around students who withdrew officially or unofficially led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should implement a procedure that documents the Seminary's review of the student’s individual facts and circumstances, including, but not limited to, documenting the date of disbursement, the date of withdrawal, and the date of determination by the institution, whether the student is deemed an official or unofficial withdrawal.
Views of Responsible Officials and Planned Corrective Actions - The financial aid director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The financial aid director created a listing to track all student withdrawals (including details of withdrawal). The registrar sends an email to the financial aid director notifying when a student has withdrawn from the institution, which gets entered onto the list. The financial aid director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and, if necessary, funds are returned to the Department of Education.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-007
Criteria - In accordance With 34 CFR § 668.164-(h)(1), a Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed for the student for allowable charges associated with that payment period. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) 14 days after the balance occurred if the credit balance occurred on the first day of class of a payment period or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition - The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of 19, audit testing identified 8 students who had a Title IV credit balance and did not receive a timely refund. The Seminary did not have appropriate documentation to retain the credit balance.
Cause and Effect - The Seminary's process for posting final charges until 30 days after the semester causes the inability to monitor credit balances on student accounts.
Recommendation - We recommend the Seminary implement procedures to post the allowable charges to the students' accounts within a timely manner and prior to the disbursement of federal funds to the students.
Views of Responsible Officials and Planned Corrective Actions - Beginning with the fall 2023 term, Title IV credit balances are no longer held past the 14 days with authorization from the student. The financial aid director implemented a new policy where students cannot request that these funds are retained beyond 14 days. There is a shared list where the business office enters the date that the student's credit balance was released to verify that process happens within 14 days.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2022-002
Criteria - The Seminary is required to perform monthly reconciliations of federal funding received between the Department of Education's records through the Common Origination and Disbursement (COD) and the Seminary's records. The Seminary is also required to have a formal review process in place to ensure the reconciliations are accurate and performed timely in accordance with 34 CFR 685.102(b), 685.301, and 303. Finally, the Seminary should have a quality assurance system in place in accordance with CFR 685.300(b)(9).
Condition - During our review of internal controls and testing procedures, it was noted that there was no evidence that reconciliations were performed or reviewed during the fiscal year. In addition, the Seminary does not have a quality assurance system in place.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Due to the lack of reconciliations performed, no reconciliations were tested. In addition, the quality assurance system was not in place.
Cause and Effect - The lack of maintaining and review of monthly reconciliations and lack of a quality assurance system could lead to differences between amounts reported to the Department of Education and amounts disbursed to the students that could go unidentified for a period of time.
Recommendation - We recommend that policies be put in place to ensure reconciliations are maintained and that a formal review process be implemented and documented. In addition, we recommend that a quality assurance process be documented and implemented to ensure compliance with loan programs.
Views of Responsible Officials and Planned Corrective Actions - Within one to two weeks of each month's end, the financial aid director requests a report from COD (U.S. Department of Education Common Origination & Disbursement) for direct loans disbursed that month. That report is retrieved through EDConnect and reviewed. The financial aid director generates a report from Jenzabar Financial Aid system of direct loans disbursed for that month. The financial aid director also retrieves a report of direct loans applied to students' accounts for that month from the business office senior accountant. These three reports are then compared and reconciled for each month.
Assistance Listing Number. Federal Agency, and Program Name - 84.268, U.S. Department of Education, Federal Direct Student Loans
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - The Seminary has 60 days from the date the Seminary determines an enrollment status change to report to NSLDS. The enrollment reporting must be updated for changes in the data elements for the campus record and the program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309).
Condition - Of the nine students selected for enrollment reporting testing, the Seminary did not properly update student enrollment information for one student in a timely manner.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Out of a sample of nine students, our testing identified one that was not properly reported as graduated when the Seminary had determined they were.
Cause and Effect - The Seminary did not have formal procedures and controls in place to document students that need to be added back to the roster to report their graduated status. The lack of documentation of withdrawn students awaiting graduation led to the inability to support the compliance with the applicable code of federal regulations in a timely manner.
Recommendation - The Seminary should consider implementing a process to submit a final enrollment file upon completion of processing graduates and reviewing procedures to verify that the information uploaded and reported is complete, accurate, and timely.
Views of Responsible Officials and Planned Corrective Actions - Students who finish their degree in December are reported as “withdrawn,” as there is no option to confer in December (institutional policy). The student status is updated to "graduated” and reported to Clearinghouse in May when students are conferred.
Assistance Listing Number. Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loan
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 688.34 for applying and monitoring satisfactory academic progress for determining eligibility of students receiving Title IV aid. Institutions are also required to have a policy that provides notification of the results of an evaluation that impacts the students eligibility for Title IV funds.
Condition - The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP).
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 19 students tested, 1 student was identified who did not meet all of the Seminary's requirements under its satisfactory academic progress policy and who should have been placed on financial aid warning prior to the disbursement of aid; however, this did not result in an ineligible disbursement, as this was the initial semester that the student fell below the requirements included in the Seminary's policy.
Cause and Effect - The Seminary's processes and controls did not identity that a student was not meeting the satisfactory academic progress policy, which could lead to the disbursement of funds to ineligible students.
Recommendation - We recommend the Seminary review its procedures and controls to ensure that students who are not in compliance with the Seminar's satisfactory academic progress policies are identified, notified, and further monitored.
Views of Responsible Officials and Corrective Action Plan - Satisfactory academic progress is now being monitored more carefully. The satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the registrar and financial aid director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the financial aid director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar Financial Aid account.