Criteria
According to 34 CFR 668.59:
(a) For the subsidized student financial assistance programs, if an applicant's FAFSA information changes as
a result of verification, the applicant or the institution must submit to the Secretary any changes to –
(1) A nondollar item; or
(2) A single dollar item of $25 or more.
(b) For the Federal Pell Grant Program, if an applicant's FAFSA information changes as a result of verification,
an institution must –
(1) Recalculate the applicant's Federal Pell Grant on the basis of the EFC on the corrected valid SAR
or valid ISIR; and
(2)
(i) Disburse any additional funds under that award only if the institution receives a corrected
valid SAR or valid ISIR for the applicant and only to the extent that additional funds are
payable based on the recalculation;
(ii) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the Federal Pell Grant award is reduced; or –
(iii) Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an
interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced.
(c) For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an
applicant's FAFSA information changes as a result of verification, the institution must –
(1) Adjust the applicant's financial aid package on the basis of the EFC on the corrected valid SAR or
valid ISIR; and
(2)
(i) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the financial aid package must be reduced;
(ii) Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an
FSEOG overpayment that is not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced; and
(iii) Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan
excess loan proceeds that are not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced. Condition
The financial aid award process includes consideration of financial and demographic data provided by the student
applicant. To evaluate the reliability of this data, a participating institution is required by the Federal Government to
select a sample from its student population and verify certain prescribed data. The selected students’ files should
be revised to incorporate any changes in the supplied data. The College’s policy is to verify the information of those
students identified by the Federal Government’s processor. During our testing, we noted 1 student, out of a sample
of 40, that did not complete verification before aid was disbursed.
Cause
The Colleges failed to have the proper review procedures in place to ensure students flagged for verification
complete verification before aid was disbursed.
Effect
The student’s EFC was calculated using incorrect data. Since the student’s EFC is used to calculate the financial
aid award, an incorrect EFC can result in an improper award.
Questioned Costs
Not applicable.
Identification as a Repeat Finding
Not applicable.
Recommendation
The Colleges should continue to strengthen their controls surrounding verification. The Colleges should implement
policies that require all student ISIR’s subject to verification be reviewed once the verification process is complete.
The reviewer should be well-versed in the verification process and requirements. Once reviewed, all verified ISIR’s
should be re-submitted to the Federal Government’s processor for recalculation of the applicant’s EFC prior to
awarding aid.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless the Colleges 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:
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 Colleges to report student enrollment changes to the National Student Loan
Data System (“NSLDS”) within 60 days.
During our testing, we noted 1 student, out of a sample of 40, that were not reported to NSLDS.
During our testing, we noted that three of the Colleges merged into one entity during year ending June 30, 2024.
We observed the records and noted 18 students out of 3,789 students did not have their NSLDS status properly
transferred to the new institution.
Cause
The Colleges did not have adequate procedures in place to ensure that status changes were properly reported to
NSLDS. The College did not have procedures in place to ensure student statuses were properly transferred during
the merger of three of the Colleges. Effect
The Colleges did not report the student’s correct status change to NSLDS, which may impact the student’s loan
grace periods and enrollment reporting statistics collected by the Department of Education.
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, were not reported to NSLDS. Of the 3,789 students merged into one institution, 18 students,
or 0.5% of merged students, were not reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The Colleges 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 status changes, the importance of reporting the correct status changes and the consequences
of incorrect reporting. Additionally, the Colleges should implement reconciliation procedures between enrollment
records and NSLDS to ensure that information is properly maintained.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 668.59:
(a) For the subsidized student financial assistance programs, if an applicant's FAFSA information changes as
a result of verification, the applicant or the institution must submit to the Secretary any changes to –
(1) A nondollar item; or
(2) A single dollar item of $25 or more.
(b) For the Federal Pell Grant Program, if an applicant's FAFSA information changes as a result of verification,
an institution must –
(1) Recalculate the applicant's Federal Pell Grant on the basis of the EFC on the corrected valid SAR
or valid ISIR; and
(2)
(i) Disburse any additional funds under that award only if the institution receives a corrected
valid SAR or valid ISIR for the applicant and only to the extent that additional funds are
payable based on the recalculation;
(ii) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the Federal Pell Grant award is reduced; or –
(iii) Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an
interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced.
(c) For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an
applicant's FAFSA information changes as a result of verification, the institution must –
(1) Adjust the applicant's financial aid package on the basis of the EFC on the corrected valid SAR or
valid ISIR; and
(2)
(i) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the financial aid package must be reduced;
(ii) Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an
FSEOG overpayment that is not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced; and
(iii) Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan
excess loan proceeds that are not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced. Condition
The financial aid award process includes consideration of financial and demographic data provided by the student
applicant. To evaluate the reliability of this data, a participating institution is required by the Federal Government to
select a sample from its student population and verify certain prescribed data. The selected students’ files should
be revised to incorporate any changes in the supplied data. The College’s policy is to verify the information of those
students identified by the Federal Government’s processor. During our testing, we noted 1 student, out of a sample
of 40, that did not complete verification before aid was disbursed.
Cause
The Colleges failed to have the proper review procedures in place to ensure students flagged for verification
complete verification before aid was disbursed.
Effect
The student’s EFC was calculated using incorrect data. Since the student’s EFC is used to calculate the financial
aid award, an incorrect EFC can result in an improper award.
Questioned Costs
Not applicable.
Identification as a Repeat Finding
Not applicable.
Recommendation
The Colleges should continue to strengthen their controls surrounding verification. The Colleges should implement
policies that require all student ISIR’s subject to verification be reviewed once the verification process is complete.
The reviewer should be well-versed in the verification process and requirements. Once reviewed, all verified ISIR’s
should be re-submitted to the Federal Government’s processor for recalculation of the applicant’s EFC prior to
awarding aid.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless the Colleges 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:
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 Colleges to report student enrollment changes to the National Student Loan
Data System (“NSLDS”) within 60 days.
During our testing, we noted 1 student, out of a sample of 40, that were not reported to NSLDS.
During our testing, we noted that three of the Colleges merged into one entity during year ending June 30, 2024.
We observed the records and noted 18 students out of 3,789 students did not have their NSLDS status properly
transferred to the new institution.
Cause
The Colleges did not have adequate procedures in place to ensure that status changes were properly reported to
NSLDS. The College did not have procedures in place to ensure student statuses were properly transferred during
the merger of three of the Colleges. Effect
The Colleges did not report the student’s correct status change to NSLDS, which may impact the student’s loan
grace periods and enrollment reporting statistics collected by the Department of Education.
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, were not reported to NSLDS. Of the 3,789 students merged into one institution, 18 students,
or 0.5% of merged students, were not reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The Colleges 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 status changes, the importance of reporting the correct status changes and the consequences
of incorrect reporting. Additionally, the Colleges should implement reconciliation procedures between enrollment
records and NSLDS to ensure that information is properly maintained.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 668.59:
(a) For the subsidized student financial assistance programs, if an applicant's FAFSA information changes as
a result of verification, the applicant or the institution must submit to the Secretary any changes to –
(1) A nondollar item; or
(2) A single dollar item of $25 or more.
(b) For the Federal Pell Grant Program, if an applicant's FAFSA information changes as a result of verification,
an institution must –
(1) Recalculate the applicant's Federal Pell Grant on the basis of the EFC on the corrected valid SAR
or valid ISIR; and
(2)
(i) Disburse any additional funds under that award only if the institution receives a corrected
valid SAR or valid ISIR for the applicant and only to the extent that additional funds are
payable based on the recalculation;
(ii) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the Federal Pell Grant award is reduced; or –
(iii) Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an
interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced.
(c) For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an
applicant's FAFSA information changes as a result of verification, the institution must –
(1) Adjust the applicant's financial aid package on the basis of the EFC on the corrected valid SAR or
valid ISIR; and
(2)
(i) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the financial aid package must be reduced;
(ii) Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an
FSEOG overpayment that is not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced; and
(iii) Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan
excess loan proceeds that are not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced. Condition
The financial aid award process includes consideration of financial and demographic data provided by the student
applicant. To evaluate the reliability of this data, a participating institution is required by the Federal Government to
select a sample from its student population and verify certain prescribed data. The selected students’ files should
be revised to incorporate any changes in the supplied data. The College’s policy is to verify the information of those
students identified by the Federal Government’s processor. During our testing, we noted 1 student, out of a sample
of 40, that did not complete verification before aid was disbursed.
Cause
The Colleges failed to have the proper review procedures in place to ensure students flagged for verification
complete verification before aid was disbursed.
Effect
The student’s EFC was calculated using incorrect data. Since the student’s EFC is used to calculate the financial
aid award, an incorrect EFC can result in an improper award.
Questioned Costs
Not applicable.
Identification as a Repeat Finding
Not applicable.
Recommendation
The Colleges should continue to strengthen their controls surrounding verification. The Colleges should implement
policies that require all student ISIR’s subject to verification be reviewed once the verification process is complete.
The reviewer should be well-versed in the verification process and requirements. Once reviewed, all verified ISIR’s
should be re-submitted to the Federal Government’s processor for recalculation of the applicant’s EFC prior to
awarding aid.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless the Colleges 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:
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 Colleges to report student enrollment changes to the National Student Loan
Data System (“NSLDS”) within 60 days.
During our testing, we noted 1 student, out of a sample of 40, that were not reported to NSLDS.
During our testing, we noted that three of the Colleges merged into one entity during year ending June 30, 2024.
We observed the records and noted 18 students out of 3,789 students did not have their NSLDS status properly
transferred to the new institution.
Cause
The Colleges did not have adequate procedures in place to ensure that status changes were properly reported to
NSLDS. The College did not have procedures in place to ensure student statuses were properly transferred during
the merger of three of the Colleges. Effect
The Colleges did not report the student’s correct status change to NSLDS, which may impact the student’s loan
grace periods and enrollment reporting statistics collected by the Department of Education.
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, were not reported to NSLDS. Of the 3,789 students merged into one institution, 18 students,
or 0.5% of merged students, were not reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The Colleges 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 status changes, the importance of reporting the correct status changes and the consequences
of incorrect reporting. Additionally, the Colleges should implement reconciliation procedures between enrollment
records and NSLDS to ensure that information is properly maintained.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 668.59:
(a) For the subsidized student financial assistance programs, if an applicant's FAFSA information changes as
a result of verification, the applicant or the institution must submit to the Secretary any changes to –
(1) A nondollar item; or
(2) A single dollar item of $25 or more.
(b) For the Federal Pell Grant Program, if an applicant's FAFSA information changes as a result of verification,
an institution must –
(1) Recalculate the applicant's Federal Pell Grant on the basis of the EFC on the corrected valid SAR
or valid ISIR; and
(2)
(i) Disburse any additional funds under that award only if the institution receives a corrected
valid SAR or valid ISIR for the applicant and only to the extent that additional funds are
payable based on the recalculation;
(ii) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the Federal Pell Grant award is reduced; or –
(iii) Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an
interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced.
(c) For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an
applicant's FAFSA information changes as a result of verification, the institution must –
(1) Adjust the applicant's financial aid package on the basis of the EFC on the corrected valid SAR or
valid ISIR; and
(2)
(i) Comply with the procedures specified in §668.61 for an interim disbursement if, as a result
of verification, the financial aid package must be reduced;
(ii) Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an
FSEOG overpayment that is not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced; and
(iii) Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan
excess loan proceeds that are not the result of an interim disbursement if, as a result of
verification, the financial aid package must be reduced. Condition
The financial aid award process includes consideration of financial and demographic data provided by the student
applicant. To evaluate the reliability of this data, a participating institution is required by the Federal Government to
select a sample from its student population and verify certain prescribed data. The selected students’ files should
be revised to incorporate any changes in the supplied data. The College’s policy is to verify the information of those
students identified by the Federal Government’s processor. During our testing, we noted 1 student, out of a sample
of 40, that did not complete verification before aid was disbursed.
Cause
The Colleges failed to have the proper review procedures in place to ensure students flagged for verification
complete verification before aid was disbursed.
Effect
The student’s EFC was calculated using incorrect data. Since the student’s EFC is used to calculate the financial
aid award, an incorrect EFC can result in an improper award.
Questioned Costs
Not applicable.
Identification as a Repeat Finding
Not applicable.
Recommendation
The Colleges should continue to strengthen their controls surrounding verification. The Colleges should implement
policies that require all student ISIR’s subject to verification be reviewed once the verification process is complete.
The reviewer should be well-versed in the verification process and requirements. Once reviewed, all verified ISIR’s
should be re-submitted to the Federal Government’s processor for recalculation of the applicant’s EFC prior to
awarding aid.
View of Responsible Officials
The Colleges agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless the Colleges 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:
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 Colleges to report student enrollment changes to the National Student Loan
Data System (“NSLDS”) within 60 days.
During our testing, we noted 1 student, out of a sample of 40, that were not reported to NSLDS.
During our testing, we noted that three of the Colleges merged into one entity during year ending June 30, 2024.
We observed the records and noted 18 students out of 3,789 students did not have their NSLDS status properly
transferred to the new institution.
Cause
The Colleges did not have adequate procedures in place to ensure that status changes were properly reported to
NSLDS. The College did not have procedures in place to ensure student statuses were properly transferred during
the merger of three of the Colleges. Effect
The Colleges did not report the student’s correct status change to NSLDS, which may impact the student’s loan
grace periods and enrollment reporting statistics collected by the Department of Education.
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, were not reported to NSLDS. Of the 3,789 students merged into one institution, 18 students,
or 0.5% of merged students, were not reported to NSLDS.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The Colleges 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 status changes, the importance of reporting the correct status changes and the consequences
of incorrect reporting. Additionally, the Colleges should implement reconciliation procedures between enrollment
records and NSLDS to ensure that information is properly maintained.
View of Responsible Officials
The Colleges agrees with the finding.