Audit 295948

Finding 2023-003 – Enrollment Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. Condition and Context: During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: • 38 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. • 2 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed in detecting that untimely information was reported to NSLDS. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: The Office of the Registrar concurs with this finding. As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance.

Finding 2023-002 – Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 Federal Pell Grant Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Institutions must report student disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context: During our testwork over 40 students who received Pell Grant funds, we identified 2 students in which the College did not accurately and timely report the disbursement to COD. Cause and Effect: The College’s control failed in detecting that untimely information was reported to COD. Isolated or Systemic: Systemic. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all Pell disbursements are reported to COD within 15 days from the initial disbursement. View of Responsible Officials: The Office of Financial Aid concurs with the audit of Pell 15-day reporting finding. The Compliance is clearly stated the timeframe to send an original Pell Grant disbursement to COD is within 15 days of the date of disbursement. We also understand we have the ability to go back into the account and make an adjustment as needed. As of September 2023, Whittier College has reached out to our software vendor Ellucian Banner to find a solution on how to avoid these incidents of not sending Pell Grant disbursements to COD in the timeframe allotted for compliance. We have now been given a new process that will solve this issue to ensure the Pell Grants are all originated on COD thus allowing the disbursements to be sent within the 15-day compliance timeframe. We will continue to reconcile the Pell Grants twice a month internally to ensure any issues get resolved, if any noted, in a timely manner.

Finding 2023-001 - Cash Management - Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 - June 30, 2023 Criteria: Per 34 CFR Section 685.300(b)(5), an institution that participates in the Direct Loan program is required to reconcile Federal funds received with actual disbursement records submitted to the Common Origination and Disbursement (COD) system monthly. Condition and Context: During our testwork over the Direct Loan Reconciliations, we noted the College failed to reconcile the Direct Loan School Account Statement (SAS) data files on a monthly basis to the internal records, and instead only performed five reconciliations for the 2022-2023 award year. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed to ensure that Direct Loan SAS data files are reconciled monthly. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure that Direct Loan SAS data files are reconciled monthly. View of Responsible Officials: The Financial Aid Office concurs with the audit finding of the monthly SAS reconciliation requirement to be done internally. Whittier College Financial Aid Staff failed to send the SAS files monthly to our Accounting Department for reconciliation. As of September 2023, Whittier College Financial Aid Office has calendared a monthly reconciliation report to be sent to the Accounting Department to meet the guidelines set forth by the Department of Education. This reconciliation report will be sent monthly through out the calendar year. In the summer months of June and July we may not have any funds to reconcile, however, a report will be sent regardless for compliance.

Finding 2023-003 – Enrollment Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. Condition and Context: During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: • 38 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. • 2 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed in detecting that untimely information was reported to NSLDS. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: The Office of the Registrar concurs with this finding. As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance.

Finding 2023-003 – Enrollment Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. Condition and Context: During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: • 38 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. • 2 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed in detecting that untimely information was reported to NSLDS. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: The Office of the Registrar concurs with this finding. As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance.

Finding 2023-002 – Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 Federal Pell Grant Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Institutions must report student disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context: During our testwork over 40 students who received Pell Grant funds, we identified 2 students in which the College did not accurately and timely report the disbursement to COD. Cause and Effect: The College’s control failed in detecting that untimely information was reported to COD. Isolated or Systemic: Systemic. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all Pell disbursements are reported to COD within 15 days from the initial disbursement. View of Responsible Officials: The Office of Financial Aid concurs with the audit of Pell 15-day reporting finding. The Compliance is clearly stated the timeframe to send an original Pell Grant disbursement to COD is within 15 days of the date of disbursement. We also understand we have the ability to go back into the account and make an adjustment as needed. As of September 2023, Whittier College has reached out to our software vendor Ellucian Banner to find a solution on how to avoid these incidents of not sending Pell Grant disbursements to COD in the timeframe allotted for compliance. We have now been given a new process that will solve this issue to ensure the Pell Grants are all originated on COD thus allowing the disbursements to be sent within the 15-day compliance timeframe. We will continue to reconcile the Pell Grants twice a month internally to ensure any issues get resolved, if any noted, in a timely manner.

Finding 2023-001 - Cash Management - Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 - June 30, 2023 Criteria: Per 34 CFR Section 685.300(b)(5), an institution that participates in the Direct Loan program is required to reconcile Federal funds received with actual disbursement records submitted to the Common Origination and Disbursement (COD) system monthly. Condition and Context: During our testwork over the Direct Loan Reconciliations, we noted the College failed to reconcile the Direct Loan School Account Statement (SAS) data files on a monthly basis to the internal records, and instead only performed five reconciliations for the 2022-2023 award year. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed to ensure that Direct Loan SAS data files are reconciled monthly. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure that Direct Loan SAS data files are reconciled monthly. View of Responsible Officials: The Financial Aid Office concurs with the audit finding of the monthly SAS reconciliation requirement to be done internally. Whittier College Financial Aid Staff failed to send the SAS files monthly to our Accounting Department for reconciliation. As of September 2023, Whittier College Financial Aid Office has calendared a monthly reconciliation report to be sent to the Accounting Department to meet the guidelines set forth by the Department of Education. This reconciliation report will be sent monthly through out the calendar year. In the summer months of June and July we may not have any funds to reconcile, however, a report will be sent regardless for compliance.

Finding 2023-003 – Enrollment Reporting – Significant Deficiency in Internal Control Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2022 – June 30, 2023 Criteria: Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. Condition and Context: During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: • 38 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. • 2 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe. Isolated or Systemic: Systemic. Cause and Effect: The College’s control failed in detecting that untimely information was reported to NSLDS. Questioned Costs: None noted. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: The Office of the Registrar concurs with this finding. As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance.