Audit 344009

Finding 2024-002 Student Financial Assistance Cluster of Programs Reporting 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 685.304(b)(2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a studyabroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. 34 CFR 685.304(b)(3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 CFR 685.309(b)(2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: A sample of thirty-seven students was selected for student file and account testing. Two students’ exit counseling was not provided. This is a repeat of prior year Finding 2023-004. Context: This was discovered during the audit testing of student files and accounts. Effect: Withdrawn students did not receive exit counseling for their direct loans in a timely manner. Cause: There appeared to be communication issues between the financial aid department and the other departments of the College. The Director of Financial Aid did not know the students had withdrawn until the audit. Recommendation: As the College has withdrawn from the Title IV program, no further recommendations are deemed necessary. Views of responsible officials: We are in agreement with this finding. Since the closure of the College will result in no further student loan activity, no immediate corrective action is considered necessary.

Finding 2024-003 Student Financial Assistance Cluster of Programs Special Tests and Provisions 84.033 Federal Work-Study Program U.S. Department of Education Criteria: 34 CFR 675.19(b)(1) An institution must follow the record retention and examination provisions in this part and in 34 CFR 668.24. 34 CFR 675.19(b)(2) The institution must also establish and maintain program and fiscal records that: (i) Include a certification by the student's supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day; (ii) Include a payroll voucher containing sufficient information to support all payroll disbursements; (iii) Include a noncash contribution record to document any payment of the institution's share of the student's earnings in the form of services and equipment (see § 675.27(a)); and (iv) Are reconciled at least monthly. Condition: A sample of thirty-seven students was selected for student file and account testing. Of those tested, thirteen earned federal work study wages during the audit period. For two of these students, the College was able to provide approved timesheets, payroll vouchers, and employment files, but was unable to locate documentation substantiating employment eligibility verification under the federal work study program. This is a repeat of prior year Finding 2023-005. Context: This was discovered during the audit testing of federal work study. Effect: The College did not have documented employment eligibility verification for federal work study students. Cause: These appeared to be isolated incidents during a time where payroll management was moved to a new department at the College.

Finding 2024-002 Student Financial Assistance Cluster of Programs Reporting 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 685.304(b)(2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a studyabroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. 34 CFR 685.304(b)(3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 CFR 685.309(b)(2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: A sample of thirty-seven students was selected for student file and account testing. Two students’ exit counseling was not provided. This is a repeat of prior year Finding 2023-004. Context: This was discovered during the audit testing of student files and accounts. Effect: Withdrawn students did not receive exit counseling for their direct loans in a timely manner. Cause: There appeared to be communication issues between the financial aid department and the other departments of the College. The Director of Financial Aid did not know the students had withdrawn until the audit. Recommendation: As the College has withdrawn from the Title IV program, no further recommendations are deemed necessary. Views of responsible officials: We are in agreement with this finding. Since the closure of the College will result in no further student loan activity, no immediate corrective action is considered necessary.

Finding 2024-003 Student Financial Assistance Cluster of Programs Special Tests and Provisions 84.033 Federal Work-Study Program U.S. Department of Education Criteria: 34 CFR 675.19(b)(1) An institution must follow the record retention and examination provisions in this part and in 34 CFR 668.24. 34 CFR 675.19(b)(2) The institution must also establish and maintain program and fiscal records that: (i) Include a certification by the student's supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day; (ii) Include a payroll voucher containing sufficient information to support all payroll disbursements; (iii) Include a noncash contribution record to document any payment of the institution's share of the student's earnings in the form of services and equipment (see § 675.27(a)); and (iv) Are reconciled at least monthly. Condition: A sample of thirty-seven students was selected for student file and account testing. Of those tested, thirteen earned federal work study wages during the audit period. For two of these students, the College was able to provide approved timesheets, payroll vouchers, and employment files, but was unable to locate documentation substantiating employment eligibility verification under the federal work study program. This is a repeat of prior year Finding 2023-005. Context: This was discovered during the audit testing of federal work study. Effect: The College did not have documented employment eligibility verification for federal work study students. Cause: These appeared to be isolated incidents during a time where payroll management was moved to a new department at the College.