Finding 2022-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Pursuant to Federal Register Volume 86, Number 119, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (?COD?) system 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 program funds are disbursed on the date that the institution credits a student?s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 86, Number 119. Of the one hundred three (103) individual Direct Loan disbursements for thirty-three (33) students selected for testing, we noted one (1) record that was not reported within the aforementioned 15-day timeframe. This one (1) Direct Loan record was reported forty-nine (49) days after the actual disbursement date. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted fourteen (14) records that were not reported within the aforementioned 15-day timeframe. These fourteen (14) Pell Grant records were reported between twenty (20) and four hundred forty (440) days after the actual disbursement date. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2022-002 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website. There are two categories of enrollment information, ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845 0002) mailboxes sent by the Department of Education (?ED?) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. 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 NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s NSLDS enrollment reporting process, we identified the following instances of noncompliance from a selection of thirty-four (34) graduated students and six (6) withdrawn students selected for enrollment reporting testing: ? Two (2) students who were never reported as graduated at either the Campus-Level or Program-Level ? Four (4) students whose published program lengths were reported incorrectly Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS throughout the entire award year.
Finding 2022-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Pursuant to Federal Register Volume 86, Number 119, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (?COD?) system 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 program funds are disbursed on the date that the institution credits a student?s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 86, Number 119. Of the one hundred three (103) individual Direct Loan disbursements for thirty-three (33) students selected for testing, we noted one (1) record that was not reported within the aforementioned 15-day timeframe. This one (1) Direct Loan record was reported forty-nine (49) days after the actual disbursement date. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted fourteen (14) records that were not reported within the aforementioned 15-day timeframe. These fourteen (14) Pell Grant records were reported between twenty (20) and four hundred forty (440) days after the actual disbursement date. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2022-002 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website. There are two categories of enrollment information, ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845 0002) mailboxes sent by the Department of Education (?ED?) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. 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 NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s NSLDS enrollment reporting process, we identified the following instances of noncompliance from a selection of thirty-four (34) graduated students and six (6) withdrawn students selected for enrollment reporting testing: ? Two (2) students who were never reported as graduated at either the Campus-Level or Program-Level ? Four (4) students whose published program lengths were reported incorrectly Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS throughout the entire award year.
Finding 2022-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Pursuant to Federal Register Volume 86, Number 119, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (?COD?) system 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 program funds are disbursed on the date that the institution credits a student?s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 86, Number 119. Of the one hundred three (103) individual Direct Loan disbursements for thirty-three (33) students selected for testing, we noted one (1) record that was not reported within the aforementioned 15-day timeframe. This one (1) Direct Loan record was reported forty-nine (49) days after the actual disbursement date. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted fourteen (14) records that were not reported within the aforementioned 15-day timeframe. These fourteen (14) Pell Grant records were reported between twenty (20) and four hundred forty (440) days after the actual disbursement date. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2022-002 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website. There are two categories of enrollment information, ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845 0002) mailboxes sent by the Department of Education (?ED?) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. 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 NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s NSLDS enrollment reporting process, we identified the following instances of noncompliance from a selection of thirty-four (34) graduated students and six (6) withdrawn students selected for enrollment reporting testing: ? Two (2) students who were never reported as graduated at either the Campus-Level or Program-Level ? Four (4) students whose published program lengths were reported incorrectly Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS throughout the entire award year.
Finding 2022-001 - Reporting - Direct Loan and Pell Common Origination and Disbursement (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Pursuant to Federal Register Volume 86, Number 119, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (?COD?) system 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 program funds are disbursed on the date that the institution credits a student?s account at the institution or pays a student or parent directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s COD reporting process, the College did not report all Direct Loan and Pell Grant disbursements to COD within the 15-day timeframe stipulated in Federal Register Volume 86, Number 119. Of the one hundred three (103) individual Direct Loan disbursements for thirty-three (33) students selected for testing, we noted one (1) record that was not reported within the aforementioned 15-day timeframe. This one (1) Direct Loan record was reported forty-nine (49) days after the actual disbursement date. Of the thirty-two (32) individual Pell Grant disbursements for seventeen (17) students selected for testing, we noted fourteen (14) records that were not reported within the aforementioned 15-day timeframe. These fourteen (14) Pell Grant records were reported between twenty (20) and four hundred forty (440) days after the actual disbursement date. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Federal Direct Loan and Pell Grant disbursements to ensure such records are submitted within the appropriate timeframe.
Finding 2022-002 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria and Context: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (?NSLDSFAP?) website. There are two categories of enrollment information, ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (?SAIG?) (OMB No. 1845 0002) mailboxes sent by the Department of Education (?ED?) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. 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 NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Due to ineffective internal controls surrounding the College?s NSLDS enrollment reporting process, we identified the following instances of noncompliance from a selection of thirty-four (34) graduated students and six (6) withdrawn students selected for enrollment reporting testing: ? Two (2) students who were never reported as graduated at either the Campus-Level or Program-Level ? Four (4) students whose published program lengths were reported incorrectly Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS throughout the entire award year.