Criteria
Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions submit
quarterly reports to the Department of Education that detail the institution's annual expenditures accurately and
that the expenditures reconcile with institution's underlying records.
Condition
During our testing, we noted that the quarterly report for quarter ending December 31, 2022, submitted by the
College and posted on the College website, was not accurate and did not reconcile with the College's underlying
records.
Cause
During quarter ending December 31, 2022, the College reported $153,380.06 in quarterly expenditures disbursed
to students. However, per underlying records, $1,153,380.06 was actually expended by the College. Inaccurate
reporting was caused by human error while preparing the report which was not identified prior to filing and posting
the report.
Effect
The College's quarterly report for quarter ending December 31, 2022, submitted to the Department of Education,
was inaccurate.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the five filed reports selected for testing,
one report, or 20% of our sample, had a reporting error.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should implement review procedures to ensure College is in compliance with the program's reporting
requirements.
View of Responsible Officials
The College agrees with the finding. The underlying documentation supporting the quarterly report for the quarter
ended December 31, 2022 was correct. However, an error was made in keying the information into the report.
Criteria
According to 34 CFR 690.83(b):
(1) An institution shall report to the Secretary any change for which a student qualifies including any
related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses
the basis and result of the change in award for each student. The institution shall submit the student’s
Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the
Federal Register.
(2) An institution shall submit, in accordance with the deadline dates established by the Secretary,
through publication in the Federal Register, other reports and information the Secretary requires and shall
comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
According to the Federal Register (Volume 86, Number 119):
An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant
disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of
the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV,
Higher Education Act (“HEA”) program funds are disbursed on the date that the institution:
(a) Credits those funds to a student’s account in the institution’s general ledger or any subledger
of the general ledger; or
(b) pays those funds to a student directly.
Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of
receiving program funds from the Department of Education.
Condition
Federal regulations require the College to report to the Federal Government’s Common Origination and
Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds
being disbursed to the student. During our testing, we noted four students out of a sample of forty were not
reported within the required timeframe by 96-280 days.
Cause
The College has policies and procedures in place to report the disbursement records to the Department of
Education through the COD system within the required fifteen calendar days; however, in this case the
procedures were not completed properly. Late reporting was due to significant personnel turnover in the financial
aid department of the College causing delay in the correction of rejected COD reporting.
Effect
The College did not report Pell Grant disbursements to COD within the required time frame.Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, four
students, or 10% of our sample, was determined to be reported late to the COD.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
We recommend that management of the College train additional financial aid department staff on the COD
reporting procedures to ensure Pell Grant funds are reported within the required timeframe when management or
other staffing has been disrupted.
View of Responsible Officials
The College agrees with the finding. The Student Financial Services department experienced significant
employee turnover in fiscal year 2023. This resulted in a disruption to the process of following up and responding
to rejected COD reporting within the required 15-day timeframe.
According to 34 CFR 668.22(f)(2):
(i) The total number of calendar days in a payment period or period of enrollment includes all days within
the period that the student was scheduled to complete, except that scheduled breaks of at least five
consecutive days are excluded from the total number of calendar days in a payment period or period
of enrollment and the number of calendar days completed in that period.
(ii) The total number of calendar days in a payment period or period of enrollment does not include –
(A) Days in which the student was on an approved leave of absence; or
(B) For a payment period or period of enrollment in which any courses in the program are offered
in modules, any scheduled breaks of at least five consecutive days when the student is not
scheduled to attend a module or other course offered during that period of time.
According to 34 CFR 668.22(e)(4):
Total amount of unearned Title IV assistance to be returned. The unearned amount of Title IV assistance
to be returned is calculated by subtracting the amount of Title IV assistance earned by the student as
calculated under paragraph (e)(1) of this section from the amount of Title IV aid that was disbursed to the
student as of the date of the institution's determination that the student withdrew.
Condition
The federal government requires that when a student withdraws from classes, the College calculate the student’s
percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes
by the total number of days in the academic period. The total number of days in the academic period (semester)
includes all calendar days between the start and end of academic activities.
The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much
Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return
of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and
returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G6”).
During our testing of forty students, we noted:
- One instance in which the incorrect number of total days in the semester was used to calculate the
student’s percentage of Title IV aid earned.
- One instance where the aid returned was different than the amount correctly calculated on the Return to
Title IV (“R2T4”) form.Cause
The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In
the instance of the incorrect number of days used in the calculation, the College incorrectly calculated the
enrollment period due to the College utilizing the incorrect semester as basis for calculating Return of Title IV
funds. The student enrolled and subsequently withdrew during Spring II semester, which is an accelerated
program. However, the College utilized the traditional Spring semester number of days in its calculation. In the
instance of the incorrect aid returned, the College did not ensure proper review of the refunding of the Title IV
funds when calculating the amount of aid to be returned.
Effect
The College did not return the appropriate amount of Title IV funds to the Department of Education.
Questioned Costs
$950.81
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2
students, or 5% of our sample, had refund amounts that were inaccurately returned to the federal government.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The College should provide training to employees responsible for completing the Return of Title IV calculations
and ensure that they have adequate knowledge in the related rules and regulations. The College should
implement a formal review process of the Return of Title IV calculations by an individual with proper knowledge of
the federal regulations.
View of Responsible Officials
The College agrees with the finding. The Student Financial Services department experienced significant
employee turnover in fiscal year 2023. The remaining staff was challenged to learn and process the Return of
Title IV calculations in a short turnaround, while being short-staffed.
Criteria
Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions submit
quarterly reports to the Department of Education that detail the institution's annual expenditures accurately and
that the expenditures reconcile with institution's underlying records.
Condition
During our testing, we noted that the quarterly report for quarter ending December 31, 2022, submitted by the
College and posted on the College website, was not accurate and did not reconcile with the College's underlying
records.
Cause
During quarter ending December 31, 2022, the College reported $153,380.06 in quarterly expenditures disbursed
to students. However, per underlying records, $1,153,380.06 was actually expended by the College. Inaccurate
reporting was caused by human error while preparing the report which was not identified prior to filing and posting
the report.
Effect
The College's quarterly report for quarter ending December 31, 2022, submitted to the Department of Education,
was inaccurate.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the five filed reports selected for testing,
one report, or 20% of our sample, had a reporting error.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should implement review procedures to ensure College is in compliance with the program's reporting
requirements.
View of Responsible Officials
The College agrees with the finding. The underlying documentation supporting the quarterly report for the quarter
ended December 31, 2022 was correct. However, an error was made in keying the information into the report.
Criteria
According to 34 CFR 690.83(b):
(1) An institution shall report to the Secretary any change for which a student qualifies including any
related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses
the basis and result of the change in award for each student. The institution shall submit the student’s
Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the
Federal Register.
(2) An institution shall submit, in accordance with the deadline dates established by the Secretary,
through publication in the Federal Register, other reports and information the Secretary requires and shall
comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
According to the Federal Register (Volume 86, Number 119):
An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant
disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of
the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV,
Higher Education Act (“HEA”) program funds are disbursed on the date that the institution:
(a) Credits those funds to a student’s account in the institution’s general ledger or any subledger
of the general ledger; or
(b) pays those funds to a student directly.
Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of
receiving program funds from the Department of Education.
Condition
Federal regulations require the College to report to the Federal Government’s Common Origination and
Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds
being disbursed to the student. During our testing, we noted four students out of a sample of forty were not
reported within the required timeframe by 96-280 days.
Cause
The College has policies and procedures in place to report the disbursement records to the Department of
Education through the COD system within the required fifteen calendar days; however, in this case the
procedures were not completed properly. Late reporting was due to significant personnel turnover in the financial
aid department of the College causing delay in the correction of rejected COD reporting.
Effect
The College did not report Pell Grant disbursements to COD within the required time frame.Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, four
students, or 10% of our sample, was determined to be reported late to the COD.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
We recommend that management of the College train additional financial aid department staff on the COD
reporting procedures to ensure Pell Grant funds are reported within the required timeframe when management or
other staffing has been disrupted.
View of Responsible Officials
The College agrees with the finding. The Student Financial Services department experienced significant
employee turnover in fiscal year 2023. This resulted in a disruption to the process of following up and responding
to rejected COD reporting within the required 15-day timeframe.
According to 34 CFR 668.22(f)(2):
(i) The total number of calendar days in a payment period or period of enrollment includes all days within
the period that the student was scheduled to complete, except that scheduled breaks of at least five
consecutive days are excluded from the total number of calendar days in a payment period or period
of enrollment and the number of calendar days completed in that period.
(ii) The total number of calendar days in a payment period or period of enrollment does not include –
(A) Days in which the student was on an approved leave of absence; or
(B) For a payment period or period of enrollment in which any courses in the program are offered
in modules, any scheduled breaks of at least five consecutive days when the student is not
scheduled to attend a module or other course offered during that period of time.
According to 34 CFR 668.22(e)(4):
Total amount of unearned Title IV assistance to be returned. The unearned amount of Title IV assistance
to be returned is calculated by subtracting the amount of Title IV assistance earned by the student as
calculated under paragraph (e)(1) of this section from the amount of Title IV aid that was disbursed to the
student as of the date of the institution's determination that the student withdrew.
Condition
The federal government requires that when a student withdraws from classes, the College calculate the student’s
percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes
by the total number of days in the academic period. The total number of days in the academic period (semester)
includes all calendar days between the start and end of academic activities.
The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much
Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return
of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and
returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G6”).
During our testing of forty students, we noted:
- One instance in which the incorrect number of total days in the semester was used to calculate the
student’s percentage of Title IV aid earned.
- One instance where the aid returned was different than the amount correctly calculated on the Return to
Title IV (“R2T4”) form.Cause
The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In
the instance of the incorrect number of days used in the calculation, the College incorrectly calculated the
enrollment period due to the College utilizing the incorrect semester as basis for calculating Return of Title IV
funds. The student enrolled and subsequently withdrew during Spring II semester, which is an accelerated
program. However, the College utilized the traditional Spring semester number of days in its calculation. In the
instance of the incorrect aid returned, the College did not ensure proper review of the refunding of the Title IV
funds when calculating the amount of aid to be returned.
Effect
The College did not return the appropriate amount of Title IV funds to the Department of Education.
Questioned Costs
$950.81
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2
students, or 5% of our sample, had refund amounts that were inaccurately returned to the federal government.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The College should provide training to employees responsible for completing the Return of Title IV calculations
and ensure that they have adequate knowledge in the related rules and regulations. The College should
implement a formal review process of the Return of Title IV calculations by an individual with proper knowledge of
the federal regulations.
View of Responsible Officials
The College agrees with the finding. The Student Financial Services department experienced significant
employee turnover in fiscal year 2023. The remaining staff was challenged to learn and process the Return of
Title IV calculations in a short turnaround, while being short-staffed.