Audit 333933

Questioned Costs $ 876 Finding No. 2024 001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to notify the student that they must repay a grant overpayment in accordance with Title IV of the Higher Education Act (“HEA”) or make satisfactory arrangements to repay such amounts, within 30 days of determining that the student withdrew. Criteria Title 34, Section 668.22(4)(ii) of the U.S. Code of Federal Regulations (“CFR”) requires that in order to recover an overpayment of a Title IV, HEA grant as a result of a student’s withdrawal from the institution, an institution must send a notice to the impacted student within 30 days of the date of the institution’s determination that the student withdrew. Cause Due to the infrequency of occurrence in which a grant overpayment in accordance with Title IV of the HEA is required, the noted instance of noncompliance may be attributed to general management oversight. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $120,666 in Title IV funds were selected for testing from a population of 104 students who withdrew and were disbursed a total of $643,193 in Title IV funds. Our test results found 1 student was not notified of a Title IV grant overpayment in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution provide notice to the impacted student that they must repay a grant overpayment in accordance with Title IV of the HEA within 30 days of the date of the institution’s determination that the student withdrew. Views of Responsible Officials and Planned Corrective Actions The institution subsequently performed a full review of students who withdrew from the institution and were disbursed Title IV funds, noting no additional instances in which a student was not notified of a Title IV grant overpayment in a timely manner. The institution also has created a checklist to assist in the completion of the identification and notification of a Title IV grant overpayment.

Questioned Costs $ -0- Finding No. 2024 002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, we noted for 5 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of (1) the payment period or period of enrollment, as applicable; (2) the academic year; or (3) the program. Cause Due to on going staffing issues within the financial aid office, the institution was unable to perform the return of the Title IV funds calculation timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $56,370 in Title IV funds were selected for testing from a population of 117 students who withdrew and were disbursed a total of $407,987 in Title IV funds. Our test results found 5 students did not have their withdrawal date determined by the institution in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution determines the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has implemented procedures to establish an internal deadline of 20 days to determine the withdrawal date for students who unofficially withdrew from the institution.

Questioned Costs $ -0- Finding No. 2024 003: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 – Federal Direct Student Loans Condition During our audit, we noted for 7 out of 10 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause The institution was training a staff member on the exit counseling process, however scheduling conflicts caused a delay that led to the notices being distributed one day after the required deadline. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 10 changes were selected for audit from a population of 35 student enrollment changes. Our test found 7 exit counseling sessions conducted with borrowers that were not performed in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution provide exit counseling to borrowers timely. Views of Responsible Officials and Planned Corrective Actions The institution has hired and trained additional personnel to assist in the timely execution of exit counseling to borrowers. The institution has also developed written instructions to assist in the execution of exit counseling to borrowers in the event of future personnel turnover.

Questioned Costs $ -0- Finding No. 2024 004: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 – Federal Direct Student Loans Condition During our audit, we noted that for 4 out of 10 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause The institution was unable to perform exit counseling to the borrowers in a timely manner due to a lack of adequate staffing leading to competing priorities and the review, analysis and dissemination of the multitude of guidance updates via electronic announcements from the U.S. Department of Education. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 10 changes were selected for audit from a population of 64 student enrollment changes. Our test found 4 exit counseling sessions conducted with borrowers that were not performed in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution provide exit counseling to borrowers timely. Views of Responsible Officials and Planned Corrective Actions The institution will examine its existing policies and procedures and provide training to newly hired personnel to assist in the timely execution of exit counseling to borrowers.

Questioned Costs $ 876 Finding No. 2024 001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to notify the student that they must repay a grant overpayment in accordance with Title IV of the Higher Education Act (“HEA”) or make satisfactory arrangements to repay such amounts, within 30 days of determining that the student withdrew. Criteria Title 34, Section 668.22(4)(ii) of the U.S. Code of Federal Regulations (“CFR”) requires that in order to recover an overpayment of a Title IV, HEA grant as a result of a student’s withdrawal from the institution, an institution must send a notice to the impacted student within 30 days of the date of the institution’s determination that the student withdrew. Cause Due to the infrequency of occurrence in which a grant overpayment in accordance with Title IV of the HEA is required, the noted instance of noncompliance may be attributed to general management oversight. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $120,666 in Title IV funds were selected for testing from a population of 104 students who withdrew and were disbursed a total of $643,193 in Title IV funds. Our test results found 1 student was not notified of a Title IV grant overpayment in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution provide notice to the impacted student that they must repay a grant overpayment in accordance with Title IV of the HEA within 30 days of the date of the institution’s determination that the student withdrew. Views of Responsible Officials and Planned Corrective Actions The institution subsequently performed a full review of students who withdrew from the institution and were disbursed Title IV funds, noting no additional instances in which a student was not notified of a Title IV grant overpayment in a timely manner. The institution also has created a checklist to assist in the completion of the identification and notification of a Title IV grant overpayment.

Questioned Costs $ -0- Finding No. 2024 002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, we noted for 5 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of (1) the payment period or period of enrollment, as applicable; (2) the academic year; or (3) the program. Cause Due to on going staffing issues within the financial aid office, the institution was unable to perform the return of the Title IV funds calculation timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $56,370 in Title IV funds were selected for testing from a population of 117 students who withdrew and were disbursed a total of $407,987 in Title IV funds. Our test results found 5 students did not have their withdrawal date determined by the institution in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution determines the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has implemented procedures to establish an internal deadline of 20 days to determine the withdrawal date for students who unofficially withdrew from the institution.

Questioned Costs $ -0- Finding No. 2024 003: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 – Federal Direct Student Loans Condition During our audit, we noted for 7 out of 10 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause The institution was training a staff member on the exit counseling process, however scheduling conflicts caused a delay that led to the notices being distributed one day after the required deadline. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 10 changes were selected for audit from a population of 35 student enrollment changes. Our test found 7 exit counseling sessions conducted with borrowers that were not performed in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution provide exit counseling to borrowers timely. Views of Responsible Officials and Planned Corrective Actions The institution has hired and trained additional personnel to assist in the timely execution of exit counseling to borrowers. The institution has also developed written instructions to assist in the execution of exit counseling to borrowers in the event of future personnel turnover.

Questioned Costs $ -0- Finding No. 2024 004: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 – Federal Direct Student Loans Condition During our audit, we noted that for 4 out of 10 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause The institution was unable to perform exit counseling to the borrowers in a timely manner due to a lack of adequate staffing leading to competing priorities and the review, analysis and dissemination of the multitude of guidance updates via electronic announcements from the U.S. Department of Education. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 10 changes were selected for audit from a population of 64 student enrollment changes. Our test found 4 exit counseling sessions conducted with borrowers that were not performed in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution provide exit counseling to borrowers timely. Views of Responsible Officials and Planned Corrective Actions The institution will examine its existing policies and procedures and provide training to newly hired personnel to assist in the timely execution of exit counseling to borrowers.