FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON
ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO
PARTICIPATE
Federal Department: Department of Education
Assistance Listing Number(s):84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV
funds received a Pell disbursement, the institution must submit the disbursement information to the
Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally,
per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete
the Fiscal Operations Report and Application to Participate (FISAP).
Condition
During our compliance testing we noted 11 out of 25 students selected for testing where the College
submitted the Pell disbursement information to the COD site after the 15 day submission window.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Questioned Costs
None
Context
A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was
submitted between 12 and 151 days late. However, it was noted during our compliance testing that the
disbursement information reported by the College to the U.S. Department of Education was accurate.
Additionally, we noted that the College was unable to provide support for amounts included in the FISAP.
Effect
The College did not apply its established controls to ensure Pell COD information was remitted timely as
well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of
support for the amounts. Thus the College was not in compliance with the reporting requirements.
Cause
The cause appears to be due to turnover in the Student Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-001.
Recommendation
We recommend that the College’s Student Financial Aid department consider additional steps to reinforce
established policies and procedures regarding timely submission of the COD information. This may
including automated reminders, updated calendars and other notification mechanisms in the College’s
Colleague system to compliment manual controls to allow for more flexibility in remote working situations.
We also recommend retaining documentation to support amounts within the FISAP.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted that the College’s population of students identified as being subject
to the return of funds for the year was not correct, as it included students that were flagged as requiring a
return of funds calculation incorrectly.
Questioned Costs
None
Context
The College initially provided a population of students that included students that were flagged as requiring
a return of funds calculation incorrectly. However, the College eventually did produce a population which
was subject to control and compliance testing that based on the selections tested, included students who
were correctly flagged as requiring return of funds calculations.
Effect
Without an accurate population, there could be a risk that control procedures applied by the College as well
as compliance with requirements for return of funds calculations may not be complete due to missing
information.
Cause
The cause appears to be an error in the processing of the file documentation would properly identify
students in the return of funds population as well as access to the archived Department of Education
submissions.
Identification as a Repeat Finding, if Applicable
This matter is considered a repeat finding, and was reported previously as finding 2023-002.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures regarding
documentation retention and population determination. We recommend that the College continue these
efforts to ensure future compliance with all applicable documentation requirements, including maintenance
of an accurate population for all semesters in which students are subject to certain compliance requirements
such as return of funds.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.
FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS
– RETURN OF FUNDS
Federal Department: Department of Education
Assistance Listing Number(s): 84.063, 84.007, 84.033
Program Name(s): Student Financial Assistance Cluster
Questioned Costs: None
Criteria
Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the
total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs and no additional disbursements may be made to the
student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through
(a)(5)).
Condition
During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term
days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned
costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days,
with dates ranging from 4 months late to 14 months late.
Questioned Costs
$12,400 (Known questioned costs of $1,240; likely questioned costs $11,160).
Context
A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days
calculated correctly, which lead to the incorrect amount of funds required to be returned being determined.
Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days.
Effect
When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be
returned is incorrectly calculated.
Cause
The cause appears to be an error in the processing of the information, due to turnover in the Student
Financial Aid department.
Identification as a Repeat Finding, if Applicable
This matter is not considered a repeat finding.
Recommendation
We are aware that the Student Financial Aid Department updates to its procedures term days calculations
and return of funds determination. We recommend that the College continue these efforts to ensure future
compliance with all applicable return of funds requirements.
Views of Responsible Officials and Planned Corrective Actions
See Corrective Action Plan.