Finding 2024-001: Eligibility
Program: Student Financial Assistance Cluster – Direct Loan Program
Assistance Listing Number (ALN): 84.268
Federal Agency: U.S. Department of Education
Federal Award Identification Number: P268K246824
Federal Award Year: June 30, 2024
Criteria: Title IV regulations require that students are eligible for Title IV funds at the time of disbursement. For students with any c codes or flags they must be resolved before disbursing Title IV funds. One such flag
is that students are not in default on any student loans (34 CFR 668.32(g)).
Condition: For 1 out of 7 students tested, the school disbursed a loan to a student that had a Perkins student loan in default and there was no support documenting that the student was not in default at the time of the disbursement.
The sample was not a statistically valid sample.
Cause: The School noted that they confirmed that the student was not in default at the time of disbursement however, did not retain support and it was noted that the student’s Institutional Student Information Record (ISIR) included a code for the default prior to the current year and again at the time of the audit.
Effect: Title IV funds were disbursed to a student that may have been in default.
Questioned costs: Federal Direct Loans ALN 84.268 $16,770.
Context: Not applicable.
Recommendation: The School should review policies and procedures to ensure all c codes or flags are cleared prior to disbursement and retain all documentation supporting their conclusions.
Management's Response: The School agrees with the finding. Procedures have been updated to ensure all verification and c-code reviews are conducted prior to disbursing of any Title IV aid. This would include maintaining documentation of clearance that is recent and up-to-date in the student’s permanent online folder.
Finding 2024-002: Significant Deficiency: Enrollment Reporting
Program: Student Financial Assistance Cluster
Assistance Listing Number (ALN): Various
Federal Agency: U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary:
(i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60
days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition: For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late.
The sample was not a statistically valid sample.
Cause: The process between financial aid and the registrar is not resulting in accurate and timely information being reported to NSLDS. The School noted the process can be improved between the registrar and financial aid for timely and accurate reporting.
Effect: Incorrect information was reported to NSLDS and information was reported late.
Questioned costs: Not applicable
Context: Not applicable.
Recommendation: The School should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students
Management's Response: The School agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation
requirements much later. The School has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly
enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline.
Finding 2024-002: Significant Deficiency: Enrollment Reporting
Program: Student Financial Assistance Cluster
Assistance Listing Number (ALN): Various
Federal Agency: U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary:
(i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60
days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition: For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late.
The sample was not a statistically valid sample.
Cause: The process between financial aid and the registrar is not resulting in accurate and timely information being reported to NSLDS. The School noted the process can be improved between the registrar and financial aid for timely and accurate reporting.
Effect: Incorrect information was reported to NSLDS and information was reported late.
Questioned costs: Not applicable
Context: Not applicable.
Recommendation: The School should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students
Management's Response: The School agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation
requirements much later. The School has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly
enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline.
Finding 2024-001: Eligibility
Program: Student Financial Assistance Cluster – Direct Loan Program
Assistance Listing Number (ALN): 84.268
Federal Agency: U.S. Department of Education
Federal Award Identification Number: P268K246824
Federal Award Year: June 30, 2024
Criteria: Title IV regulations require that students are eligible for Title IV funds at the time of disbursement. For students with any c codes or flags they must be resolved before disbursing Title IV funds. One such flag
is that students are not in default on any student loans (34 CFR 668.32(g)).
Condition: For 1 out of 7 students tested, the school disbursed a loan to a student that had a Perkins student loan in default and there was no support documenting that the student was not in default at the time of the disbursement.
The sample was not a statistically valid sample.
Cause: The School noted that they confirmed that the student was not in default at the time of disbursement however, did not retain support and it was noted that the student’s Institutional Student Information Record (ISIR) included a code for the default prior to the current year and again at the time of the audit.
Effect: Title IV funds were disbursed to a student that may have been in default.
Questioned costs: Federal Direct Loans ALN 84.268 $16,770.
Context: Not applicable.
Recommendation: The School should review policies and procedures to ensure all c codes or flags are cleared prior to disbursement and retain all documentation supporting their conclusions.
Management's Response: The School agrees with the finding. Procedures have been updated to ensure all verification and c-code reviews are conducted prior to disbursing of any Title IV aid. This would include maintaining documentation of clearance that is recent and up-to-date in the student’s permanent online folder.
Finding 2024-002: Significant Deficiency: Enrollment Reporting
Program: Student Financial Assistance Cluster
Assistance Listing Number (ALN): Various
Federal Agency: U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary:
(i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60
days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition: For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late.
The sample was not a statistically valid sample.
Cause: The process between financial aid and the registrar is not resulting in accurate and timely information being reported to NSLDS. The School noted the process can be improved between the registrar and financial aid for timely and accurate reporting.
Effect: Incorrect information was reported to NSLDS and information was reported late.
Questioned costs: Not applicable
Context: Not applicable.
Recommendation: The School should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students
Management's Response: The School agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation
requirements much later. The School has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly
enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline.
Finding 2024-002: Significant Deficiency: Enrollment Reporting
Program: Student Financial Assistance Cluster
Assistance Listing Number (ALN): Various
Federal Agency: U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary:
(i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60
days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition: For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late.
The sample was not a statistically valid sample.
Cause: The process between financial aid and the registrar is not resulting in accurate and timely information being reported to NSLDS. The School noted the process can be improved between the registrar and financial aid for timely and accurate reporting.
Effect: Incorrect information was reported to NSLDS and information was reported late.
Questioned costs: Not applicable
Context: Not applicable.
Recommendation: The School should revise its procedures to ensure NSLDS enrollment reporting is completed accurately and timely for all status changes and all students
Management's Response: The School agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation
requirements much later. The School has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly
enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline.