2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-005: Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school 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.
Condition/context: Of the 24 students selected for testing:
• Seven students’ withdrawn status was not reported to the National Student Loan Data System (NSLDS).
• Eight students were not reported to NSLDS with an accurate withdrawal date.
• Eight students’ statuses were not reported timely to NSLDS.
Cause: The College was following institutional policy, which was not compliant with 34 CFR 690.83 or 34 CFR 685.309.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, improper reporting of student status changes could impact students’ interest subsidy, repayment status, and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-005: Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school 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.
Condition/context: Of the 24 students selected for testing:
• Seven students’ withdrawn status was not reported to the National Student Loan Data System (NSLDS).
• Eight students were not reported to NSLDS with an accurate withdrawal date.
• Eight students’ statuses were not reported timely to NSLDS.
Cause: The College was following institutional policy, which was not compliant with 34 CFR 690.83 or 34 CFR 685.309.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, improper reporting of student status changes could impact students’ interest subsidy, repayment status, and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-003: Student Financial Assistance Cluster - Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; and #84.033, Federal Work-Study Program
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year, an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall ensure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition/context: The College was unable to provide documentation that supported the information reported in Part II, Section D, Line 7(a) and Part II, Section E, Line 22.
Cause: The College does not have controls in place to retain all documentation utilized in preparation of the Fiscal Operations Report and Application to Participate (FISAP).
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure that all reports, queries, etc. utilized in the preparation of the FISAP are retained.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-003: Student Financial Assistance Cluster - Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; and #84.033, Federal Work-Study Program
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year, an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall ensure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition/context: The College was unable to provide documentation that supported the information reported in Part II, Section D, Line 7(a) and Part II, Section E, Line 22.
Cause: The College does not have controls in place to retain all documentation utilized in preparation of the Fiscal Operations Report and Application to Participate (FISAP).
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure that all reports, queries, etc. utilized in the preparation of the FISAP are retained.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-005: Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school 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.
Condition/context: Of the 24 students selected for testing:
• Seven students’ withdrawn status was not reported to the National Student Loan Data System (NSLDS).
• Eight students were not reported to NSLDS with an accurate withdrawal date.
• Eight students’ statuses were not reported timely to NSLDS.
Cause: The College was following institutional policy, which was not compliant with 34 CFR 690.83 or 34 CFR 685.309.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, improper reporting of student status changes could impact students’ interest subsidy, repayment status, and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-005: Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school 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.
Condition/context: Of the 24 students selected for testing:
• Seven students’ withdrawn status was not reported to the National Student Loan Data System (NSLDS).
• Eight students were not reported to NSLDS with an accurate withdrawal date.
• Eight students’ statuses were not reported timely to NSLDS.
Cause: The College was following institutional policy, which was not compliant with 34 CFR 690.83 or 34 CFR 685.309.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, improper reporting of student status changes could impact students’ interest subsidy, repayment status, and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-003: Student Financial Assistance Cluster - Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; and #84.033, Federal Work-Study Program
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year, an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall ensure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition/context: The College was unable to provide documentation that supported the information reported in Part II, Section D, Line 7(a) and Part II, Section E, Line 22.
Cause: The College does not have controls in place to retain all documentation utilized in preparation of the Fiscal Operations Report and Application to Participate (FISAP).
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure that all reports, queries, etc. utilized in the preparation of the FISAP are retained.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-003: Student Financial Assistance Cluster - Reporting (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; and #84.033, Federal Work-Study Program
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year, an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall ensure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition/context: The College was unable to provide documentation that supported the information reported in Part II, Section D, Line 7(a) and Part II, Section E, Line 22.
Cause: The College does not have controls in place to retain all documentation utilized in preparation of the Fiscal Operations Report and Application to Participate (FISAP).
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement controls to ensure that all reports, queries, etc. utilized in the preparation of the FISAP are retained.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2024-004: Student Financial Assistance Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Numbers/Titles: #84.007, Federal Supplemental Educational Opportunity Grants; #84.033, Federal Work-Study Program; #84.063, Federal Pell Grant Program; and #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Award Number: N/A
Award Year: July 1, 2023 - June 30, 2024
Criteria: Per 34 CFR 668.165(a)(1), before an institution disburses Title IV funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV program, and how and when those funds will be disbursed.
Condition/context: The College’s award notifications do not include when the funds will be disbursed. As such, this information was not included in the files of all 25 students selected for testing.
Cause: The College believed that it was compliant by sending notifications on the day of disbursement.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should include the disbursement date in award notifications or refer to the academic calendar (which includes disbursement dates) in all award notifications.
Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.