Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 36 CFR Section 686.165(2).
Condition: We tested 26 Direct Loan recipients and 1 TEACH Grant recipient for eligibility, and noted that the 26 and 1 sampled, respectively, were not notified of their right to cancel their loan or TEACH Grant, or notified of the the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Cause: The College did not have a procedure in place to properly notify students or parents of their right to cancel their loan or TEACH Grant, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel their loan or TEACH Grant.
Effect: The provisions of 36 CFR Section 686.165(2) were not followed and thus a total of 27 students were not notified of their right to cancel their loan or TEACH Grant, nor were they notified of the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College update their disbursement letter to students or parents to include wording about the right to cancel their loan or TEACH Grant and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
View of responsible officials and planned corrective actions: The disbursement letter that we previously had notified they had the right to decline their loans. As with the recommendation of our auditor, the letters wording has already been changed from the right to decline their loan to the right to cancel their loan. Letter also states that the request must be received by KWC within 14 days of the date on the notice.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 36 CFR Section 686.165(2).
Condition: We tested 26 Direct Loan recipients and 1 TEACH Grant recipient for eligibility, and noted that the 26 and 1 sampled, respectively, were not notified of their right to cancel their loan or TEACH Grant, or notified of the the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Cause: The College did not have a procedure in place to properly notify students or parents of their right to cancel their loan or TEACH Grant, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel their loan or TEACH Grant.
Effect: The provisions of 36 CFR Section 686.165(2) were not followed and thus a total of 27 students were not notified of their right to cancel their loan or TEACH Grant, nor were they notified of the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College update their disbursement letter to students or parents to include wording about the right to cancel their loan or TEACH Grant and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
View of responsible officials and planned corrective actions: The disbursement letter that we previously had notified they had the right to decline their loans. As with the recommendation of our auditor, the letters wording has already been changed from the right to decline their loan to the right to cancel their loan. Letter also states that the request must be received by KWC within 14 days of the date on the notice.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant Program, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a).
Condition: We tested 40 samples for eligibility, and noted that 10 of the samples had errors reporting disbursement dates and/or amounts to Common Origination and Disbursement (COD). 8 students had the incorrect disbursement date on COD. 1 student had a disbursement on COD that was never disbursed to the student. 1 student had a disbursement on their account statement that was not recorded as disbursed in COD.
Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD.
Effect: The provisions of 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a) were not followed and thus a total of 10 students had incorrect reporting in COD.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student account.
View of responsible officials and planned corrective actions: The College will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College's Business Office.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant Program, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a).
Condition: We tested 40 samples for eligibility, and noted that 10 of the samples had errors reporting disbursement dates and/or amounts to Common Origination and Disbursement (COD). 8 students had the incorrect disbursement date on COD. 1 student had a disbursement on COD that was never disbursed to the student. 1 student had a disbursement on their account statement that was not recorded as disbursed in COD.
Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD.
Effect: The provisions of 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a) were not followed and thus a total of 10 students had incorrect reporting in COD.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student account.
View of responsible officials and planned corrective actions: The College will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College's Business Office.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant Program, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a).
Condition: We tested 40 samples for eligibility, and noted that 10 of the samples had errors reporting disbursement dates and/or amounts to Common Origination and Disbursement (COD). 8 students had the incorrect disbursement date on COD. 1 student had a disbursement on COD that was never disbursed to the student. 1 student had a disbursement on their account statement that was not recorded as disbursed in COD.
Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD.
Effect: The provisions of 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a) were not followed and thus a total of 10 students had incorrect reporting in COD.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student account.
View of responsible officials and planned corrective actions: The College will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College's Business Office.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 685.203.
Condition: We tested 26 Direct Loan recipients as part of testing for eligibility, and noted 3 instances where students received an incorrect amount of Direct Loans based on their student classification, and received more Direct Loans than allowed.
Cause: The College's Information Technology (IT) system packaged the student's financial aid based on the student's classification from the Institutional Student Information Records (ISIR), instead of using the transcript. The students had filled out the ISIR incorrectly based on their classification per the College's student classification policy, causing the student to get disbursed the incorrect amount of Direct Loans.
Effect: The provisions of 34 Section 685.203 were not followed, and 3 students received more Direct Loans than which they were eligible.
Questioned Costs: 1 student was a first year by credit hours, but received the loan limits for a second year, resulting in the student receiving $1,000 more subsidized loans than they were eligible. 1 student was a second year by credit hours, but received the loan limits for a third year, resulting in the student receiving $1,000 more subsidized loans than they were eligible. 1 student was an independent second year by credit hours, but received the loan limits for a third year, resulting in the student receiving $1,000 more subsidized loans and $1,000 more unsubsidized loans than they were eligible. The total questioned costs were $4,000, with $3,000 in subsidized loans and $1,000 in unsubsidized loans.
Recommendation: We recommend that the College update procedures to use proper information for packaging and to review student classification prior to disbursing a Direct Loan to verify the student is receiving the proper amount.
View of responsible officials and planned corrective actions: The College has updated its procedure to include a report to be reviewed of credits earned to verify the amounts to be disbursed to the student is in compliance standards of the correct grade level for Direct Loans. All financial aid staff has been updated on the procedures to review the Direct Loan amounts to credits earned when packaging the student and a final approval from either the Assistant Director of Financial Aid or the Director of Financial Aid before the award letter is sent to the student.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 685.309(b).
Condition: During our testing of student status changes for graduates, we noted 2 students, out of our sample of 15 for which the National Student Loan Data System (NSLDS) was not notified timely of the correct student status change. 2 graduates from the Fall semester during the fiscal year ended May 31, 2024 were not reported to the NSLDS within 60 days of the graduation date.
Cause: The graduated status for 2 students was not reported to the NSLDS in a timely manner.
Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus some students were not reported timely and subsequently were not placed into loan repayment status in a timely manner.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the College submit roster files on a regular basis.
View of responsible officials and planned corrective actions: The Registrar's Office will review the enrollment roster before the information is uploaded to the National Student Clearinghouse and will do a second review of the report that the National Student Clearinghouse will populate upon processing the enrollment roster. The Registrar's Office will send enrollment rosters every 30 days to the National Student Clearinghouse. Graduate roster will be sent to the National Student Clearinghouse within 60 days of degree completion.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of official withdrawals, we reviewed the calculation used by the College for the return of funds and noted 2 instances of the wrong withdrawal date being used in the return of funds calculation.
Cause: The College does not have a procedure in place to properly review the withdrawal date used in the return of funds calculations.
Effect: The provisions of 34 CFR Section 668.22 were not followed and thus 2 students had incorrect return of funds calculations.
Questioned Costs: Known questioned costs total $16 that should have been returned and $219 that should not have been returned as a result of our testing.
Recommendation: We recommend that the College review and revise their policies and procedures related to the return of funds calculation. The College should ensure the correct withdrawal date is used the return of funds calculation. Additional training should be provided to relevant staff on the proper calculation methods to enhance compliance and accuracy.
View of responsible officials and planned corrective actions: The College has reviewed its policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of official withdrawals, we reviewed the calculation used by the College for the return of funds and noted 2 instances of the wrong withdrawal date being used in the return of funds calculation.
Cause: The College does not have a procedure in place to properly review the withdrawal date used in the return of funds calculations.
Effect: The provisions of 34 CFR Section 668.22 were not followed and thus 2 students had incorrect return of funds calculations.
Questioned Costs: Known questioned costs total $16 that should have been returned and $219 that should not have been returned as a result of our testing.
Recommendation: We recommend that the College review and revise their policies and procedures related to the return of funds calculation. The College should ensure the correct withdrawal date is used the return of funds calculation. Additional training should be provided to relevant staff on the proper calculation methods to enhance compliance and accuracy.
View of responsible officials and planned corrective actions: The College has reviewed its policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of official withdrawals, we reviewed the calculation used by the College for the return of funds and noted 2 instances of the wrong withdrawal date being used in the return of funds calculation.
Cause: The College does not have a procedure in place to properly review the withdrawal date used in the return of funds calculations.
Effect: The provisions of 34 CFR Section 668.22 were not followed and thus 2 students had incorrect return of funds calculations.
Questioned Costs: Known questioned costs total $16 that should have been returned and $219 that should not have been returned as a result of our testing.
Recommendation: We recommend that the College review and revise their policies and procedures related to the return of funds calculation. The College should ensure the correct withdrawal date is used the return of funds calculation. Additional training should be provided to relevant staff on the proper calculation methods to enhance compliance and accuracy.
View of responsible officials and planned corrective actions: The College has reviewed its policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: We tested 3 official withdrawals as part of testing for official withdrawals, and noted 2 instances where a student was eligible for a post-withdrawal disbursement, and the College did not timely provide the required written notification to the students.
Cause: Written notification was not provided to 2 students who were eligible for post-withdrawal disbursements.
Effect: 2 students were not notified of required written notifications. The provisions of 34 CFR Section 622.22(a)(6) were not followed.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College implement a control to ensure students that are eligible for a post-withdrawal disbursement are notified timely the required written notifications.
View of responsible officials and planned corrective actions: The College will have the Director of Financial Aid to send the post-withdrawal disbursement letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal disbursement letter is to be sent, it will be recorded and logged on the same spreadsheet the Financial Aid Office tracks withdrawals.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: We tested 3 official withdrawals as part of testing for official withdrawals, and noted 2 instances where a student was eligible for a post-withdrawal disbursement, and the College did not timely provide the required written notification to the students.
Cause: Written notification was not provided to 2 students who were eligible for post-withdrawal disbursements.
Effect: 2 students were not notified of required written notifications. The provisions of 34 CFR Section 622.22(a)(6) were not followed.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College implement a control to ensure students that are eligible for a post-withdrawal disbursement are notified timely the required written notifications.
View of responsible officials and planned corrective actions: The College will have the Director of Financial Aid to send the post-withdrawal disbursement letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal disbursement letter is to be sent, it will be recorded and logged on the same spreadsheet the Financial Aid Office tracks withdrawals.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 36 CFR Section 686.165(2).
Condition: We tested 26 Direct Loan recipients and 1 TEACH Grant recipient for eligibility, and noted that the 26 and 1 sampled, respectively, were not notified of their right to cancel their loan or TEACH Grant, or notified of the the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Cause: The College did not have a procedure in place to properly notify students or parents of their right to cancel their loan or TEACH Grant, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel their loan or TEACH Grant.
Effect: The provisions of 36 CFR Section 686.165(2) were not followed and thus a total of 27 students were not notified of their right to cancel their loan or TEACH Grant, nor were they notified of the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College update their disbursement letter to students or parents to include wording about the right to cancel their loan or TEACH Grant and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
View of responsible officials and planned corrective actions: The disbursement letter that we previously had notified they had the right to decline their loans. As with the recommendation of our auditor, the letters wording has already been changed from the right to decline their loan to the right to cancel their loan. Letter also states that the request must be received by KWC within 14 days of the date on the notice.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 36 CFR Section 686.165(2).
Condition: We tested 26 Direct Loan recipients and 1 TEACH Grant recipient for eligibility, and noted that the 26 and 1 sampled, respectively, were not notified of their right to cancel their loan or TEACH Grant, or notified of the the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Cause: The College did not have a procedure in place to properly notify students or parents of their right to cancel their loan or TEACH Grant, and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel their loan or TEACH Grant.
Effect: The provisions of 36 CFR Section 686.165(2) were not followed and thus a total of 27 students were not notified of their right to cancel their loan or TEACH Grant, nor were they notified of the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College update their disbursement letter to students or parents to include wording about the right to cancel their loan or TEACH Grant and the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or TEACH Grant.
View of responsible officials and planned corrective actions: The disbursement letter that we previously had notified they had the right to decline their loans. As with the recommendation of our auditor, the letters wording has already been changed from the right to decline their loan to the right to cancel their loan. Letter also states that the request must be received by KWC within 14 days of the date on the notice.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant Program, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a).
Condition: We tested 40 samples for eligibility, and noted that 10 of the samples had errors reporting disbursement dates and/or amounts to Common Origination and Disbursement (COD). 8 students had the incorrect disbursement date on COD. 1 student had a disbursement on COD that was never disbursed to the student. 1 student had a disbursement on their account statement that was not recorded as disbursed in COD.
Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD.
Effect: The provisions of 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a) were not followed and thus a total of 10 students had incorrect reporting in COD.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student account.
View of responsible officials and planned corrective actions: The College will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College's Business Office.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant Program, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a).
Condition: We tested 40 samples for eligibility, and noted that 10 of the samples had errors reporting disbursement dates and/or amounts to Common Origination and Disbursement (COD). 8 students had the incorrect disbursement date on COD. 1 student had a disbursement on COD that was never disbursed to the student. 1 student had a disbursement on their account statement that was not recorded as disbursed in COD.
Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD.
Effect: The provisions of 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a) were not followed and thus a total of 10 students had incorrect reporting in COD.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student account.
View of responsible officials and planned corrective actions: The College will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College's Business Office.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant Program, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College and Higher Education Grant (TEACH Grant), Assistance Listing 84.379
Criteria: The College must comply with 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a).
Condition: We tested 40 samples for eligibility, and noted that 10 of the samples had errors reporting disbursement dates and/or amounts to Common Origination and Disbursement (COD). 8 students had the incorrect disbursement date on COD. 1 student had a disbursement on COD that was never disbursed to the student. 1 student had a disbursement on their account statement that was not recorded as disbursed in COD.
Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD.
Effect: The provisions of 34 CFR 690.83, 34 Section 685.301(a)(2), and 34 CFR Section 686.37(a) were not followed and thus a total of 10 students had incorrect reporting in COD.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student account.
View of responsible officials and planned corrective actions: The College will review and verify the funds that were disbursed to the students account match the disbursement dates in COD on the date the transfer batch report is sent to the College's Business Office.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 685.203.
Condition: We tested 26 Direct Loan recipients as part of testing for eligibility, and noted 3 instances where students received an incorrect amount of Direct Loans based on their student classification, and received more Direct Loans than allowed.
Cause: The College's Information Technology (IT) system packaged the student's financial aid based on the student's classification from the Institutional Student Information Records (ISIR), instead of using the transcript. The students had filled out the ISIR incorrectly based on their classification per the College's student classification policy, causing the student to get disbursed the incorrect amount of Direct Loans.
Effect: The provisions of 34 Section 685.203 were not followed, and 3 students received more Direct Loans than which they were eligible.
Questioned Costs: 1 student was a first year by credit hours, but received the loan limits for a second year, resulting in the student receiving $1,000 more subsidized loans than they were eligible. 1 student was a second year by credit hours, but received the loan limits for a third year, resulting in the student receiving $1,000 more subsidized loans than they were eligible. 1 student was an independent second year by credit hours, but received the loan limits for a third year, resulting in the student receiving $1,000 more subsidized loans and $1,000 more unsubsidized loans than they were eligible. The total questioned costs were $4,000, with $3,000 in subsidized loans and $1,000 in unsubsidized loans.
Recommendation: We recommend that the College update procedures to use proper information for packaging and to review student classification prior to disbursing a Direct Loan to verify the student is receiving the proper amount.
View of responsible officials and planned corrective actions: The College has updated its procedure to include a report to be reviewed of credits earned to verify the amounts to be disbursed to the student is in compliance standards of the correct grade level for Direct Loans. All financial aid staff has been updated on the procedures to review the Direct Loan amounts to credits earned when packaging the student and a final approval from either the Assistant Director of Financial Aid or the Director of Financial Aid before the award letter is sent to the student.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 685.309(b).
Condition: During our testing of student status changes for graduates, we noted 2 students, out of our sample of 15 for which the National Student Loan Data System (NSLDS) was not notified timely of the correct student status change. 2 graduates from the Fall semester during the fiscal year ended May 31, 2024 were not reported to the NSLDS within 60 days of the graduation date.
Cause: The graduated status for 2 students was not reported to the NSLDS in a timely manner.
Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus some students were not reported timely and subsequently were not placed into loan repayment status in a timely manner.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the College submit roster files on a regular basis.
View of responsible officials and planned corrective actions: The Registrar's Office will review the enrollment roster before the information is uploaded to the National Student Clearinghouse and will do a second review of the report that the National Student Clearinghouse will populate upon processing the enrollment roster. The Registrar's Office will send enrollment rosters every 30 days to the National Student Clearinghouse. Graduate roster will be sent to the National Student Clearinghouse within 60 days of degree completion.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Federal Work Study Program, Assistance Listing 84.038
Federal Direct Loan Program, Assistance Listing 84.268
Teacher Education Assistance for College Higher Education Grants, Assistance Listing 84.379
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of unofficial withdrawals, we selected 6 samples and noted 3 students who did not complete the enrollment period that did not have a return of funds calculation performed timely. 1 of the students had a calculation performed subsequent to the auditors discovery. The other 2 students did not have a return of funds calculation performed.
Cause: The College did not have a control in place to properly review students who unofficially withdrew to verify the student completed the enrollment period. For those students who unofficially withdrew and did not complete the enrollment period, there was no control in place to verify a return of funds calculation was being performed timely.
Effect: There was 1 student who did not have a return of funds calculation performed timely, as well as 2 students who did not have a return of funds calculation performed.
Questioned Costs: Known questioned costs of $998 of aid that was returned untimely, due to the return of funds calculation being performed lately. Known questioned costs of $4,361 of funds that should have been returned that were not, due to return of funds calculation not being performed.
Recommendation: We recommend that the College review and revise their policies and procedures related to unofficial withdrawals. The College should review the last day attended for all students who unofficially withdrew, to determine if a return of funds calculation is necessary.
View of responsible officials and planned corrective actions: The College is not an attendance taking school and will not be using the last date attended, but the College has implemented procedure to use the last date of an academic activity as standard for a non-attendance taking school. At the end of each semester, the College has put a procedure in place to review all grades within 7 business days of final grades being reported. Once reviewed, the Director of Financial Aid will send an email to all faculty for the student to request that last date of an academic activity for on-ground students. For online students, the Director of Online Learning will provide the last date of an academic activity recorded in the online platform. Once the last date of academic activity has been provided to the Financial Office, that date will be used in the return of funds calculation. The College will process all return of funds calculations before the standard 45 day timeframe.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of official withdrawals, we reviewed the calculation used by the College for the return of funds and noted 2 instances of the wrong withdrawal date being used in the return of funds calculation.
Cause: The College does not have a procedure in place to properly review the withdrawal date used in the return of funds calculations.
Effect: The provisions of 34 CFR Section 668.22 were not followed and thus 2 students had incorrect return of funds calculations.
Questioned Costs: Known questioned costs total $16 that should have been returned and $219 that should not have been returned as a result of our testing.
Recommendation: We recommend that the College review and revise their policies and procedures related to the return of funds calculation. The College should ensure the correct withdrawal date is used the return of funds calculation. Additional training should be provided to relevant staff on the proper calculation methods to enhance compliance and accuracy.
View of responsible officials and planned corrective actions: The College has reviewed its policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of official withdrawals, we reviewed the calculation used by the College for the return of funds and noted 2 instances of the wrong withdrawal date being used in the return of funds calculation.
Cause: The College does not have a procedure in place to properly review the withdrawal date used in the return of funds calculations.
Effect: The provisions of 34 CFR Section 668.22 were not followed and thus 2 students had incorrect return of funds calculations.
Questioned Costs: Known questioned costs total $16 that should have been returned and $219 that should not have been returned as a result of our testing.
Recommendation: We recommend that the College review and revise their policies and procedures related to the return of funds calculation. The College should ensure the correct withdrawal date is used the return of funds calculation. Additional training should be provided to relevant staff on the proper calculation methods to enhance compliance and accuracy.
View of responsible officials and planned corrective actions: The College has reviewed its policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Federal Supplemental Education Opportunity Grant, Assistance Listing 84.007
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: During our testing of official withdrawals, we reviewed the calculation used by the College for the return of funds and noted 2 instances of the wrong withdrawal date being used in the return of funds calculation.
Cause: The College does not have a procedure in place to properly review the withdrawal date used in the return of funds calculations.
Effect: The provisions of 34 CFR Section 668.22 were not followed and thus 2 students had incorrect return of funds calculations.
Questioned Costs: Known questioned costs total $16 that should have been returned and $219 that should not have been returned as a result of our testing.
Recommendation: We recommend that the College review and revise their policies and procedures related to the return of funds calculation. The College should ensure the correct withdrawal date is used the return of funds calculation. Additional training should be provided to relevant staff on the proper calculation methods to enhance compliance and accuracy.
View of responsible officials and planned corrective actions: The College has reviewed its policies and procedures related to return of funds calculations. When a student wants to withdraw from the College, the student will complete an online withdrawal form. Once the form is completed, an electronic copy of the form is sent to several offices, Financial Aid being included. The Financial Aid Office will use the date on the electronic withdraw form in the Return of Title IV calculation.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: We tested 3 official withdrawals as part of testing for official withdrawals, and noted 2 instances where a student was eligible for a post-withdrawal disbursement, and the College did not timely provide the required written notification to the students.
Cause: Written notification was not provided to 2 students who were eligible for post-withdrawal disbursements.
Effect: 2 students were not notified of required written notifications. The provisions of 34 CFR Section 622.22(a)(6) were not followed.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College implement a control to ensure students that are eligible for a post-withdrawal disbursement are notified timely the required written notifications.
View of responsible officials and planned corrective actions: The College will have the Director of Financial Aid to send the post-withdrawal disbursement letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal disbursement letter is to be sent, it will be recorded and logged on the same spreadsheet the Financial Aid Office tracks withdrawals.
Federal Program:
U.S. Department of Education:
Student Financial Aid Cluster:
Federal Pell Grant, Assistance Listing 84.063
Direct Loan Program, Assistance Listing 84.268
Criteria: The College must comply with 34 Section 668.22.
Condition: We tested 3 official withdrawals as part of testing for official withdrawals, and noted 2 instances where a student was eligible for a post-withdrawal disbursement, and the College did not timely provide the required written notification to the students.
Cause: Written notification was not provided to 2 students who were eligible for post-withdrawal disbursements.
Effect: 2 students were not notified of required written notifications. The provisions of 34 CFR Section 622.22(a)(6) were not followed.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the College implement a control to ensure students that are eligible for a post-withdrawal disbursement are notified timely the required written notifications.
View of responsible officials and planned corrective actions: The College will have the Director of Financial Aid to send the post-withdrawal disbursement letter the same day as performing the return of funds calculations which will be well within the 45 day requirement. If a post-withdrawal disbursement letter is to be sent, it will be recorded and logged on the same spreadsheet the Financial Aid Office tracks withdrawals.