Criteria
According to 34 CFR 685.203(j):
Maximum loan amounts. In no case may a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended, less –
(1) The student’s estimated financial assistance for that period; and
(2) In the case of a Direct Subsidized Loan, the borrower’s expected family contribution for that period.
According to 2 CFR Part 200, Appendix XI of the Compliance Supplement updated April 2022:
In determining loan amounts for unsubsidized Stafford loans, the financial aid administrator subtracts from the COA, the EFC and the estimated financial assistance for the period of enrollment that the student (or parent on behalf of the student) will receive from federal, state, institutional or other sources. Unsubsidized Stafford loans, PLUS loans, loans made by a school to assist the student, and State-sponsored loans may be used to substitute for EFC.
According to Volume 3 Page 143 of the 2018-2019 Student Financial Aid Handbook:
Except for Pell Grants, FSA (“federal student aid”) award amounts are also constrained by the other aid that a student receives, known as Estimated Financial Assistance. The general rule is that the student’s total aid may not exceed the student’s financial need (Need = Cost of Attendance minus EFC).
The cost of attendance for the Campus-Based, TEACH Grant, and Direct/Direct PLUS Loan programs is based on the student’s enrollment status and costs for the period in which the aid is intended. The Cost of Attendance used for Pell Grants and Iraq & Afghanistan Service Grants is always the full-year costs for a full-time student, so you may have to prorate actual or average costs up for students who are attending less than an academic year (or who are part-time in a term program) or prorate down for students who are attending for periods longer than an academic year.
Condition
The Financial Aid Department is responsible for awarding federal, state and institutional financial aid. The Federal Government requires the College to compare the student’s Cost of Attendance (“COA”) with the student’s Estimated Family Contribution (“EFC”) and Estimated Financial Assistance (“EFA”). EFA must include all grants and scholarships the College anticipates the student will receive regardless of the source. The total aid awarded to a student cannot exceed the student’s COA. Financial aid awarded by outside sources is often sent directly to the Bursar to be applied against the student’s account. The Bursar notifies the Financial Aid Department to ensure the outside aid is included in the student’s EFA. During our testing, we noted 1 student, out of a sample of 40, that received aid in excess of their financial need and cost of attendance.
Cause
The Student Financial Services Office failed to notify the Financial Aid Office of outside aid received on behalf of a student who received other financial aid. As a result, the student’s EFA was incorrect.
Effect
The Financial Aid Department awarded the student financial aid based on an incorrect EFA. As a result, the student received federal and state grants, federal loans and private loans that in total exceeded their cost of attendance.
Questioned Costs
$533
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was awarded financial aid in excess of the student’s cost of attendance.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should create formal procedures for when aid is sent directly to the Student Financial Services Office. These procedures should include a review of the student’s billing statement to determine if the financial aid has been disbursed and timely notification of the aid to the Financial Aid Office. Once the Financial Aid Office is notified of the outside aid, the student’s financial aid award should be reviewed to determine if any adjustment needs to be made to the award.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.203(j):
Maximum loan amounts. In no case may a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended, less –
(1) The student’s estimated financial assistance for that period; and
(2) In the case of a Direct Subsidized Loan, the borrower’s expected family contribution for that period.
According to 2 CFR Part 200, Appendix XI of the Compliance Supplement updated April 2022:
In determining loan amounts for unsubsidized Stafford loans, the financial aid administrator subtracts from the COA, the EFC and the estimated financial assistance for the period of enrollment that the student (or parent on behalf of the student) will receive from federal, state, institutional or other sources. Unsubsidized Stafford loans, PLUS loans, loans made by a school to assist the student, and State-sponsored loans may be used to substitute for EFC.
According to Volume 3 Page 143 of the 2018-2019 Student Financial Aid Handbook:
Except for Pell Grants, FSA (“federal student aid”) award amounts are also constrained by the other aid that a student receives, known as Estimated Financial Assistance. The general rule is that the student’s total aid may not exceed the student’s financial need (Need = Cost of Attendance minus EFC).
The cost of attendance for the Campus-Based, TEACH Grant, and Direct/Direct PLUS Loan programs is based on the student’s enrollment status and costs for the period in which the aid is intended. The Cost of Attendance used for Pell Grants and Iraq & Afghanistan Service Grants is always the full-year costs for a full-time student, so you may have to prorate actual or average costs up for students who are attending less than an academic year (or who are part-time in a term program) or prorate down for students who are attending for periods longer than an academic year.
Condition
The Financial Aid Department is responsible for awarding federal, state and institutional financial aid. The Federal Government requires the College to compare the student’s Cost of Attendance (“COA”) with the student’s Estimated Family Contribution (“EFC”) and Estimated Financial Assistance (“EFA”). EFA must include all grants and scholarships the College anticipates the student will receive regardless of the source. The total aid awarded to a student cannot exceed the student’s COA. Financial aid awarded by outside sources is often sent directly to the Bursar to be applied against the student’s account. The Bursar notifies the Financial Aid Department to ensure the outside aid is included in the student’s EFA. During our testing, we noted 1 student, out of a sample of 40, that received aid in excess of their financial need and cost of attendance.
Cause
The Student Financial Services Office failed to notify the Financial Aid Office of outside aid received on behalf of a student who received other financial aid. As a result, the student’s EFA was incorrect.
Effect
The Financial Aid Department awarded the student financial aid based on an incorrect EFA. As a result, the student received federal and state grants, federal loans and private loans that in total exceeded their cost of attendance.
Questioned Costs
$533
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was awarded financial aid in excess of the student’s cost of attendance.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should create formal procedures for when aid is sent directly to the Student Financial Services Office. These procedures should include a review of the student’s billing statement to determine if the financial aid has been disbursed and timely notification of the aid to the Financial Aid Office. Once the Financial Aid Office is notified of the outside aid, the student’s financial aid award should be reviewed to determine if any adjustment needs to be made to the award.
View of Responsible Officials
The College agrees with the finding.
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 83, Number 233):
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.
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 1 student, out of a sample of 40, was not reported within the required timeframe by 22 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.
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 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 22 days.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 3 students, out of a sample of 40, were not reported to NSLDS within the required timeframe.
Cause
The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe.
Effect
The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods..
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe 10-63 days.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 8 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS.
Cause
The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS.
Effect
The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 8 students, or 20% of our sample, had incorrect effective dates reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 8 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS.
Cause
The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS.
Effect
The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 8 students, or 20% of our sample, had incorrect effective dates reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.203(j):
Maximum loan amounts. In no case may a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended, less –
(1) The student’s estimated financial assistance for that period; and
(2) In the case of a Direct Subsidized Loan, the borrower’s expected family contribution for that period.
According to 2 CFR Part 200, Appendix XI of the Compliance Supplement updated April 2022:
In determining loan amounts for unsubsidized Stafford loans, the financial aid administrator subtracts from the COA, the EFC and the estimated financial assistance for the period of enrollment that the student (or parent on behalf of the student) will receive from federal, state, institutional or other sources. Unsubsidized Stafford loans, PLUS loans, loans made by a school to assist the student, and State-sponsored loans may be used to substitute for EFC.
According to Volume 3 Page 143 of the 2018-2019 Student Financial Aid Handbook:
Except for Pell Grants, FSA (“federal student aid”) award amounts are also constrained by the other aid that a student receives, known as Estimated Financial Assistance. The general rule is that the student’s total aid may not exceed the student’s financial need (Need = Cost of Attendance minus EFC).
The cost of attendance for the Campus-Based, TEACH Grant, and Direct/Direct PLUS Loan programs is based on the student’s enrollment status and costs for the period in which the aid is intended. The Cost of Attendance used for Pell Grants and Iraq & Afghanistan Service Grants is always the full-year costs for a full-time student, so you may have to prorate actual or average costs up for students who are attending less than an academic year (or who are part-time in a term program) or prorate down for students who are attending for periods longer than an academic year.
Condition
The Financial Aid Department is responsible for awarding federal, state and institutional financial aid. The Federal Government requires the College to compare the student’s Cost of Attendance (“COA”) with the student’s Estimated Family Contribution (“EFC”) and Estimated Financial Assistance (“EFA”). EFA must include all grants and scholarships the College anticipates the student will receive regardless of the source. The total aid awarded to a student cannot exceed the student’s COA. Financial aid awarded by outside sources is often sent directly to the Bursar to be applied against the student’s account. The Bursar notifies the Financial Aid Department to ensure the outside aid is included in the student’s EFA. During our testing, we noted 1 student, out of a sample of 40, that received aid in excess of their financial need and cost of attendance.
Cause
The Student Financial Services Office failed to notify the Financial Aid Office of outside aid received on behalf of a student who received other financial aid. As a result, the student’s EFA was incorrect.
Effect
The Financial Aid Department awarded the student financial aid based on an incorrect EFA. As a result, the student received federal and state grants, federal loans and private loans that in total exceeded their cost of attendance.
Questioned Costs
$533
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was awarded financial aid in excess of the student’s cost of attendance.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should create formal procedures for when aid is sent directly to the Student Financial Services Office. These procedures should include a review of the student’s billing statement to determine if the financial aid has been disbursed and timely notification of the aid to the Financial Aid Office. Once the Financial Aid Office is notified of the outside aid, the student’s financial aid award should be reviewed to determine if any adjustment needs to be made to the award.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.203(j):
Maximum loan amounts. In no case may a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended, less –
(1) The student’s estimated financial assistance for that period; and
(2) In the case of a Direct Subsidized Loan, the borrower’s expected family contribution for that period.
According to 2 CFR Part 200, Appendix XI of the Compliance Supplement updated April 2022:
In determining loan amounts for unsubsidized Stafford loans, the financial aid administrator subtracts from the COA, the EFC and the estimated financial assistance for the period of enrollment that the student (or parent on behalf of the student) will receive from federal, state, institutional or other sources. Unsubsidized Stafford loans, PLUS loans, loans made by a school to assist the student, and State-sponsored loans may be used to substitute for EFC.
According to Volume 3 Page 143 of the 2018-2019 Student Financial Aid Handbook:
Except for Pell Grants, FSA (“federal student aid”) award amounts are also constrained by the other aid that a student receives, known as Estimated Financial Assistance. The general rule is that the student’s total aid may not exceed the student’s financial need (Need = Cost of Attendance minus EFC).
The cost of attendance for the Campus-Based, TEACH Grant, and Direct/Direct PLUS Loan programs is based on the student’s enrollment status and costs for the period in which the aid is intended. The Cost of Attendance used for Pell Grants and Iraq & Afghanistan Service Grants is always the full-year costs for a full-time student, so you may have to prorate actual or average costs up for students who are attending less than an academic year (or who are part-time in a term program) or prorate down for students who are attending for periods longer than an academic year.
Condition
The Financial Aid Department is responsible for awarding federal, state and institutional financial aid. The Federal Government requires the College to compare the student’s Cost of Attendance (“COA”) with the student’s Estimated Family Contribution (“EFC”) and Estimated Financial Assistance (“EFA”). EFA must include all grants and scholarships the College anticipates the student will receive regardless of the source. The total aid awarded to a student cannot exceed the student’s COA. Financial aid awarded by outside sources is often sent directly to the Bursar to be applied against the student’s account. The Bursar notifies the Financial Aid Department to ensure the outside aid is included in the student’s EFA. During our testing, we noted 1 student, out of a sample of 40, that received aid in excess of their financial need and cost of attendance.
Cause
The Student Financial Services Office failed to notify the Financial Aid Office of outside aid received on behalf of a student who received other financial aid. As a result, the student’s EFA was incorrect.
Effect
The Financial Aid Department awarded the student financial aid based on an incorrect EFA. As a result, the student received federal and state grants, federal loans and private loans that in total exceeded their cost of attendance.
Questioned Costs
$533
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was awarded financial aid in excess of the student’s cost of attendance.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should create formal procedures for when aid is sent directly to the Student Financial Services Office. These procedures should include a review of the student’s billing statement to determine if the financial aid has been disbursed and timely notification of the aid to the Financial Aid Office. Once the Financial Aid Office is notified of the outside aid, the student’s financial aid award should be reviewed to determine if any adjustment needs to be made to the award.
View of Responsible Officials
The College agrees with the finding.
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 83, Number 233):
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.
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 1 student, out of a sample of 40, was not reported within the required timeframe by 22 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.
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 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 22 days.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 3 students, out of a sample of 40, were not reported to NSLDS within the required timeframe.
Cause
The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe.
Effect
The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods..
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe 10-63 days.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 8 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS.
Cause
The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS.
Effect
The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 8 students, or 20% of our sample, had incorrect effective dates reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 8 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS.
Cause
The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS.
Effect
The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 8 students, or 20% of our sample, had incorrect effective dates reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College.
View of Responsible Officials
The College agrees with the finding.