Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Reporting
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Pell Grant Program, #84.063
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Reporting – Institutions must submit Pell origination and disbursement records to the Department of Education COD system. The origination records include social security number, award number, enrollment date, verification status code, transaction number, cost of attendance, academic start date, academic end date, disbursement date, and disbursement amount.
Condition – The College records did not match the origination data submitted to the Department of Education COD system for certain Pell recipients with regards to enrollment date and academic start date.
Questions Costs – None.
Context – For five out of a sample of 25 Pell recipients selected for testing, the enrollment date and the academic start date per the College’s records did not match the dates submitted to the Department of Education COD system. The dates that were submitted were in the fall term and dated in August of 2022 but the recipient’s enrollment and academic start date should have been in the spring or summer terms (January or May of 2023).
Effect – Due to the origination records not matching as described above, the College is not in compliance with the reporting requirement.
Cause – The College incorrectly submitted enrollment and academic start dates in the fall term but should have been in the spring and summer terms.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to ensure the correct enrollment and academic start dates are submitted to the Department of Education’s COD system.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update reporting procedures to ensure the correct academic start dates and enrollment dates are submitted to the Department of Education’s COD system.
Enrollment Reporting
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – Under the Pell grant and loan programs, colleges must complete and return within 15 days the Enrollment Reporting roster file. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the National Student Loan Data System (NSLDS) website. Colleges are responsible for timely reporting, whether they report directly or via a third-party servicer. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Condition – Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required time frame. In addition, the status change per the College’s records did not consistently match what was reported in the NSLDS’s enrollment detail.
Questions Costs – None.
Context – Out of a sample of 25 students from a population of 752 students receiving Pell grants or loans and which had a change in status during the year, NSLDS was not provided timely notification for 5 of the student status changes reported and tested. For the five, the notification occurred after 138 days when should have been reported within 60 days. Our sampling method was not, and was not intended to be, statistically valid.
Effect – Student status changes exceeded the 60-day period for student enrollment changes reported in roster files.
Cause – The College did not consistently report enrollment changes within 60 days.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College develop and implement procedures to help ensure all student status changes and errors in enrollment reporting batch process are reported within the required timeframes.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Enrollment Reporting
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – Under the Pell grant and loan programs, colleges must complete and return within 15 days the Enrollment Reporting roster file. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the National Student Loan Data System (NSLDS) website. Colleges are responsible for timely reporting, whether they report directly or via a third-party servicer. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Condition – Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required time frame. In addition, the status change per the College’s records did not consistently match what was reported in the NSLDS’s enrollment detail.
Questions Costs – None.
Context – Out of a sample of 25 students from a population of 752 students receiving Pell grants or loans and which had a change in status during the year, NSLDS was not provided timely notification for 5 of the student status changes reported and tested. For the five, the notification occurred after 138 days when should have been reported within 60 days. Our sampling method was not, and was not intended to be, statistically valid.
Effect – Student status changes exceeded the 60-day period for student enrollment changes reported in roster files.
Cause – The College did not consistently report enrollment changes within 60 days.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College develop and implement procedures to help ensure all student status changes and errors in enrollment reporting batch process are reported within the required timeframes.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Reporting
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Pell Grant Program, #84.063
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Reporting – Institutions must submit Pell origination and disbursement records to the Department of Education COD system. The origination records include social security number, award number, enrollment date, verification status code, transaction number, cost of attendance, academic start date, academic end date, disbursement date, and disbursement amount.
Condition – The College records did not match the origination data submitted to the Department of Education COD system for certain Pell recipients with regards to enrollment date and academic start date.
Questions Costs – None.
Context – For five out of a sample of 25 Pell recipients selected for testing, the enrollment date and the academic start date per the College’s records did not match the dates submitted to the Department of Education COD system. The dates that were submitted were in the fall term and dated in August of 2022 but the recipient’s enrollment and academic start date should have been in the spring or summer terms (January or May of 2023).
Effect – Due to the origination records not matching as described above, the College is not in compliance with the reporting requirement.
Cause – The College incorrectly submitted enrollment and academic start dates in the fall term but should have been in the spring and summer terms.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to ensure the correct enrollment and academic start dates are submitted to the Department of Education’s COD system.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update reporting procedures to ensure the correct academic start dates and enrollment dates are submitted to the Department of Education’s COD system.
Enrollment Reporting
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – Under the Pell grant and loan programs, colleges must complete and return within 15 days the Enrollment Reporting roster file. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the National Student Loan Data System (NSLDS) website. Colleges are responsible for timely reporting, whether they report directly or via a third-party servicer. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Condition – Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required time frame. In addition, the status change per the College’s records did not consistently match what was reported in the NSLDS’s enrollment detail.
Questions Costs – None.
Context – Out of a sample of 25 students from a population of 752 students receiving Pell grants or loans and which had a change in status during the year, NSLDS was not provided timely notification for 5 of the student status changes reported and tested. For the five, the notification occurred after 138 days when should have been reported within 60 days. Our sampling method was not, and was not intended to be, statistically valid.
Effect – Student status changes exceeded the 60-day period for student enrollment changes reported in roster files.
Cause – The College did not consistently report enrollment changes within 60 days.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College develop and implement procedures to help ensure all student status changes and errors in enrollment reporting batch process are reported within the required timeframes.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Return of Title IV Funds
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program,
#84.007; Federal Work-Study Program, #84.033; Federal Pell Grant Program, #84.063; Federal Direct Student Loan Program, #84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition – The College utilized an incorrect academic start date for use in its Return to Title IV calculations.
Questions Costs – The utilization of an incorrect start date within the College’s Colleague system resulted in overpayments of the institutional portion of the amount to return of $99 and underpayments of the institutional portion of the amount to return of $31 – net difference of an overpayment in the amount of $68.
Context – A sample of 31 was selected from a population of 209 recipients that were subject to return of Title IV funds calculation. The College incorrectly calculated the number of days in the academic term for five recipients. The start date utilized was off by one day and this resulted in a difference in the amount calculated of $68 for the five recipients.
Effect – Due to the incorrect number of days used in the academic term for the return of funds calculation, the College did not calculate correctly the return of Title IV funds calculations for five students.
Cause – The College incorrectly calculated the days that should be included in the academic term used in the return of Title IV calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College implement policies and procedures to review, update, and verify academic term information used for the return of Title IV funds calculations.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the return of Title IV funds calculation.
Enrollment Reporting
Federal Program – U.S. Department of Education (ED), Student Financial Assistance Cluster, Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268.
Program Year – July 1, 2022 - June 30, 2023
Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – Under the Pell grant and loan programs, colleges must complete and return within 15 days the Enrollment Reporting roster file. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the National Student Loan Data System (NSLDS) website. Colleges are responsible for timely reporting, whether they report directly or via a third-party servicer. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Condition – Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required time frame. In addition, the status change per the College’s records did not consistently match what was reported in the NSLDS’s enrollment detail.
Questions Costs – None.
Context – Out of a sample of 25 students from a population of 752 students receiving Pell grants or loans and which had a change in status during the year, NSLDS was not provided timely notification for 5 of the student status changes reported and tested. For the five, the notification occurred after 138 days when should have been reported within 60 days. Our sampling method was not, and was not intended to be, statistically valid.
Effect – Student status changes exceeded the 60-day period for student enrollment changes reported in roster files.
Cause – The College did not consistently report enrollment changes within 60 days.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – We recommend the College develop and implement procedures to help ensure all student status changes and errors in enrollment reporting batch process are reported within the required timeframes.
Views of Responsible Officials and Planned Corrective Actions – Concur. The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported.