2024-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.
Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants.
We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $143
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.”
Condition: During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans.
We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year findings 2023-003 and 2023-006.
Statistical sampling was not used in making sample selections.
Questioned Costs: $3,199
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-004 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College had made corrections to individuals’ accounts that were not reported and reflected in COD.
Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections.
Questioned Costs: $350
Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections.
Questioned Costs: $350
Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections.
Questioned Costs: $350
Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.
Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants.
We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $143
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.”
Condition: During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans.
We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year findings 2023-003 and 2023-006.
Statistical sampling was not used in making sample selections.
Questioned Costs: $3,199
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-004 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College had made corrections to individuals’ accounts that were not reported and reflected in COD.
Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections.
Questioned Costs: $350
Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections.
Questioned Costs: $350
Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024
Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections.
Questioned Costs: $350
Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.