2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Department of Education, SFA Cluster Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the school’s Campus Based Program funding for the upcoming award year as well as report Campus‑Based Program expenditures for the prior award year. The College is required to submit a Fiscal Operations Report plus other information required; the information must be accurate and shall be submitted on the form at the time specified, 34 CFR 674.19(d)(2). Condition: During our review of the College’s FISAP it was determined that tuition and fee revenue was overstated and Pell amount reported was understated. Cause: Tuition and fee revenue reported on the FISAP included deferred tuition and fees that that were not recognized until the subsequent year. Pell was understated due to preparation of the FISAP before a reconciliation was completed. Effect: Incorrect reporting of information may cause federal funding for the College to be over-awarded or under-awarded in subsequent years. In addition, failure to accurately report the College’s FISAP may jeopardize future federal funding. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College improve procedures to ensure accurate reporting. Management Response: We concur with this finding. Staff made a “change request” to the U.S. Department of Education (USDOE) to adjust the FISAP. Once the “change request” was approved by the USDOE, we edited the FISAP report to appropriately reflect the audited numbers. It is important to note that the FISAP is due by September 30th, and the USDOE allows institutions until December 15th to adjust the figures. Our audited financial statements are due no later than September 30th, which normally allows time to ensure that the figures on the FISAP are reconciled to the ones on the audited financial statements. Nevertheless, if the audited statements are not completed by the September 30th deadline, we will make sure that any adjusting entries to the FISAP are made by the final date of December 15th.
2023-002 Disbursement of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Cause: Administrative oversight. Effect: Not processing awards timely results in inaccurate student accounts and may result in students being awarded Title IV Direct Loans in excess of the cumulative limitations in a subsequent period of enrollment. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College implement procedures to ensure that all Title IV Direct Loans accepted by students are disbursed timely. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester.
2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Department of Education, SFA Cluster Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 140 students that received all failing grades in a term, we tested fourteen students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Cause: The College considers students that receive a grade of F to have attended the entire period, however, no written attendance policy exists to this effect and no documentation could be provided to support the last day of the student’s attendance at an academically related subject. Effect: Since there is no formal written policy requiring instructors to utilize different grades for students that fail a class after attending the entire term and for students that failed to attend through the end of the term, it is unclear whether the student attended through the end of the period. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College implement a policy in which instructors are required to retain documentation of a student’s last date of attendance and the grades assigned to a student failing a class indicate whether the student attended through the end of the period or stopped attending prior to the end of the period. In addition, we recommend documentation of a student’s last date of attendance at an academically related class be maintained. Management Response: We concur with this finding. With enhancements to the Jenzabar ONE system, the institution has implemented a new process that requires professors to enter the Last Day of attendance (LDA) for any student who earned an F grade. Going forward, the Registrar will present a report to the Office of Financial Aid two days after final grades post for the semester. The report will have the students who have all Fs with their LDS listed for each class.
2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Department of Education Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a 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. If a student withdrawals by providing notification to designated officials, the withdrawal date is the date notification was provided. Institutional charges used in the refund calculation are the charges that were initially assessed the student for the entire payment period. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that four of the seven had refund calculations prepared. From these calculations we noted the following: 1. Breaks of five or more consecutive days were not deducted from total days in all refunds. 2. The date of the college’s determination was used as the withdrawal date for three of the four students. 3. Institutional charges for the period used in the refund calculation included tuition and fee credits processed due to the withdrawal for two of the four students. Cause: The College’s Thanksgiving break of five consecutive days and Spring break of nine consecutive days were not deducted from the total days in the semester for any refund calculation during the fiscal year. Three of the student’s refund calculations were prepared using the college’s date of determination instead of the date of the student’s withdrawal. The college processed a credit for tuition and fees when the student withdrew, and this credit reduced institutional charges in the refund calculation for two of the four students. Effect: The refund was incorrect for all four students that had refund calculations prepared. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College put procedures in place for accurate preparation and calculation of Title IV refunds. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training on R2T4 processing along with other regulations. System updates are performed during the Fall semester for the next year. During this update, R2T4 parameters are set and monitored to ensure accuracy. In addition, the R2T4 calculations now include adjustments made to the students’ account at the time of withdrawal.
2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Department of Education, SFA Cluster Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. The change in status was not reported to NSLDS for one student and the last date of the semester was reported instead of the withdrawal date for four students. Cause: Incorrect date or no date was reported in NSLDS Enrollment Reporting. Effect: The Department of Education was unaware of the student’s withdrawal; thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Repeat Finding from Prior Year: No. Recommendation: We recommend that a review process be put in place to ensure complete and accurate NSLDS reporting of student withdrawal dates. Management Response: The Registrar’s Office maintains the institution’s enrollment records. During the fall of 2023, the enrollment reporting process was moved to the Registrar’s Office to ensure the accuracy of reporting.
2023-006 Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. Four of the students refund calculations were not completed in a timely fashion and two students that completed a withdrawal form did not have a refund calculations prepared. The College did not return Title IV funds for the two students that should have had refund calculations and the College did not return Title IV funds within 45 days after the date of determination of the student’s withdrawal for the four students that had refund calculations prepared. Cause: The two students that did not have refund calculations prepared withdrew electronically, however the withdrawal was not communicated to the Financial Aid Department in order to have a refund processed. Due to this, the students were considered by the College to have attended the entire semester and received failing grades for all classes. The refund calculations that were prepared for four students were prepared more than 45 days after the date of determination, thus, funds were returned more than 45 days after the date of determination of the student’s withdrawal date. Effect: The two students that withdrew but were not processed received failing grades in their classes instead of being withdrawn from their classes and no refund calculation was prepared. The four students that had refund calculations prepared were not prepared timely, resulting in Title IV funds not being returned timely. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College put a process in place to ensure student withdrawal requests are processed properly and timely, and Title IV funds are returned timely. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the communication list for withdrawals was updated with the Director of Financial Aid’s information to ensure the financial aid office receives all withdrawal information in a timely manner.
2023-007 Exit Counseling (Significant Deficiency) Department of Education, SFA Cluster Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower’s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: During our testing, we noted eight instances, in a sample of nine students requiring exit counseling, in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates. Repeat Finding from a Prior Year: Yes. Recommendation: We recommend the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this counseling should be retained by the College. Management Response: We concur with this finding. Currently, students receive a withdrawal notification that provides them with a link to complete their exit counseling. Moving forward and during the completion of the withdrawal, the students will be presented with an exit counseling digital page. On this page, withdrawal information will be provided to the student along with the deadline to complete the exit counseling. Students will also certify that they have received and understood the information. Once the withdrawal form is completed, students will get a follow up email that will also direct them to the exit counseling at www.studentaid.gov and inform them of the 30-day deadline.
2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Department of Education, SFA Cluster Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the school’s Campus Based Program funding for the upcoming award year as well as report Campus‑Based Program expenditures for the prior award year. The College is required to submit a Fiscal Operations Report plus other information required; the information must be accurate and shall be submitted on the form at the time specified, 34 CFR 674.19(d)(2). Condition: During our review of the College’s FISAP it was determined that tuition and fee revenue was overstated and Pell amount reported was understated. Cause: Tuition and fee revenue reported on the FISAP included deferred tuition and fees that that were not recognized until the subsequent year. Pell was understated due to preparation of the FISAP before a reconciliation was completed. Effect: Incorrect reporting of information may cause federal funding for the College to be over-awarded or under-awarded in subsequent years. In addition, failure to accurately report the College’s FISAP may jeopardize future federal funding. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College improve procedures to ensure accurate reporting. Management Response: We concur with this finding. Staff made a “change request” to the U.S. Department of Education (USDOE) to adjust the FISAP. Once the “change request” was approved by the USDOE, we edited the FISAP report to appropriately reflect the audited numbers. It is important to note that the FISAP is due by September 30th, and the USDOE allows institutions until December 15th to adjust the figures. Our audited financial statements are due no later than September 30th, which normally allows time to ensure that the figures on the FISAP are reconciled to the ones on the audited financial statements. Nevertheless, if the audited statements are not completed by the September 30th deadline, we will make sure that any adjusting entries to the FISAP are made by the final date of December 15th.
2023-002 Disbursement of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Cause: Administrative oversight. Effect: Not processing awards timely results in inaccurate student accounts and may result in students being awarded Title IV Direct Loans in excess of the cumulative limitations in a subsequent period of enrollment. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College implement procedures to ensure that all Title IV Direct Loans accepted by students are disbursed timely. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester.
2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Department of Education, SFA Cluster Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 140 students that received all failing grades in a term, we tested fourteen students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Cause: The College considers students that receive a grade of F to have attended the entire period, however, no written attendance policy exists to this effect and no documentation could be provided to support the last day of the student’s attendance at an academically related subject. Effect: Since there is no formal written policy requiring instructors to utilize different grades for students that fail a class after attending the entire term and for students that failed to attend through the end of the term, it is unclear whether the student attended through the end of the period. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College implement a policy in which instructors are required to retain documentation of a student’s last date of attendance and the grades assigned to a student failing a class indicate whether the student attended through the end of the period or stopped attending prior to the end of the period. In addition, we recommend documentation of a student’s last date of attendance at an academically related class be maintained. Management Response: We concur with this finding. With enhancements to the Jenzabar ONE system, the institution has implemented a new process that requires professors to enter the Last Day of attendance (LDA) for any student who earned an F grade. Going forward, the Registrar will present a report to the Office of Financial Aid two days after final grades post for the semester. The report will have the students who have all Fs with their LDS listed for each class.
2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Department of Education Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a 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. If a student withdrawals by providing notification to designated officials, the withdrawal date is the date notification was provided. Institutional charges used in the refund calculation are the charges that were initially assessed the student for the entire payment period. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that four of the seven had refund calculations prepared. From these calculations we noted the following: 1. Breaks of five or more consecutive days were not deducted from total days in all refunds. 2. The date of the college’s determination was used as the withdrawal date for three of the four students. 3. Institutional charges for the period used in the refund calculation included tuition and fee credits processed due to the withdrawal for two of the four students. Cause: The College’s Thanksgiving break of five consecutive days and Spring break of nine consecutive days were not deducted from the total days in the semester for any refund calculation during the fiscal year. Three of the student’s refund calculations were prepared using the college’s date of determination instead of the date of the student’s withdrawal. The college processed a credit for tuition and fees when the student withdrew, and this credit reduced institutional charges in the refund calculation for two of the four students. Effect: The refund was incorrect for all four students that had refund calculations prepared. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College put procedures in place for accurate preparation and calculation of Title IV refunds. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training on R2T4 processing along with other regulations. System updates are performed during the Fall semester for the next year. During this update, R2T4 parameters are set and monitored to ensure accuracy. In addition, the R2T4 calculations now include adjustments made to the students’ account at the time of withdrawal.
2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Department of Education, SFA Cluster Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. The change in status was not reported to NSLDS for one student and the last date of the semester was reported instead of the withdrawal date for four students. Cause: Incorrect date or no date was reported in NSLDS Enrollment Reporting. Effect: The Department of Education was unaware of the student’s withdrawal; thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Repeat Finding from Prior Year: No. Recommendation: We recommend that a review process be put in place to ensure complete and accurate NSLDS reporting of student withdrawal dates. Management Response: The Registrar’s Office maintains the institution’s enrollment records. During the fall of 2023, the enrollment reporting process was moved to the Registrar’s Office to ensure the accuracy of reporting.
2023-006 Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. Four of the students refund calculations were not completed in a timely fashion and two students that completed a withdrawal form did not have a refund calculations prepared. The College did not return Title IV funds for the two students that should have had refund calculations and the College did not return Title IV funds within 45 days after the date of determination of the student’s withdrawal for the four students that had refund calculations prepared. Cause: The two students that did not have refund calculations prepared withdrew electronically, however the withdrawal was not communicated to the Financial Aid Department in order to have a refund processed. Due to this, the students were considered by the College to have attended the entire semester and received failing grades for all classes. The refund calculations that were prepared for four students were prepared more than 45 days after the date of determination, thus, funds were returned more than 45 days after the date of determination of the student’s withdrawal date. Effect: The two students that withdrew but were not processed received failing grades in their classes instead of being withdrawn from their classes and no refund calculation was prepared. The four students that had refund calculations prepared were not prepared timely, resulting in Title IV funds not being returned timely. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College put a process in place to ensure student withdrawal requests are processed properly and timely, and Title IV funds are returned timely. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the communication list for withdrawals was updated with the Director of Financial Aid’s information to ensure the financial aid office receives all withdrawal information in a timely manner.
2023-007 Exit Counseling (Significant Deficiency) Department of Education, SFA Cluster Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower’s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: During our testing, we noted eight instances, in a sample of nine students requiring exit counseling, in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates. Repeat Finding from a Prior Year: Yes. Recommendation: We recommend the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this counseling should be retained by the College. Management Response: We concur with this finding. Currently, students receive a withdrawal notification that provides them with a link to complete their exit counseling. Moving forward and during the completion of the withdrawal, the students will be presented with an exit counseling digital page. On this page, withdrawal information will be provided to the student along with the deadline to complete the exit counseling. Students will also certify that they have received and understood the information. Once the withdrawal form is completed, students will get a follow up email that will also direct them to the exit counseling at www.studentaid.gov and inform them of the 30-day deadline.