Finding 2024-001: Eligibility-Pell Grant (Significant Deficiency)
Federal Program - Federal Pell Grant Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN - 84.063
Federal Award Year - June 30, 2024
Criteria: 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 (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student's enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts.
Condition/Context: For one student out of 40 tested, the student was selected for, and completed, verification prior to the College disbursing funds for the Fall 2023 term. As a result of that verification, the student's Expected Family Contribution (EFC) decreased and the College received a valid, corrected ISIR. However, the student's award package was not updated as a result of the decreased EFC. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: A corrected ISIR came in after verification was complete and the review and re-packaging process never occurred.
Effect: The student was not awarded the appropriate amount of Federal Pell Grant funds based on the student's lower, corrected EFC.
Questioned Costs: $400
Recommendation: We recommend that a step is added to the College's standard verification procedures to ensure that Federal Pell Grant awards are appropriately adjusted for any changes in EFC that are the result of a completed verification.
Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed away. This happened due to human error. We have a process in place to monitor corrected ISIR transactions to ensure that the EFC (SAI effective for award year 2024-25 and later) agrees with our documentation. The student record is then given to the director for final review and repackaging. We have added an additional step now whereby the Pell Grant administrator also reviews the output report for ISIR imports on a weekly basis.
Finding 2024-002: Enrollment Reporting (Significant Deficiency)
Federal Program - Federal Direct Student Loans, Federal Pell Grant Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN - 84.268, 84.063
Federal Award Year - June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition/Context: For 4 of the 25 students tested, their enrollment status was incorrectly reported as withdrawn to the National Student Loan Data Systems (NSLDS). The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the College. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate and could affect student loan repayments.
Questioned Costs: None
Recommendation: The College should review its policy on enrollment reporting to NSLDS to ensure all status changes during the year are reported in a timely and accurate manner.
Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting.
Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.
Finding 2024-002: Enrollment Reporting (Significant Deficiency)
Federal Program - Federal Direct Student Loans, Federal Pell Grant Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN - 84.268, 84.063
Federal Award Year - June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition/Context: For 4 of the 25 students tested, their enrollment status was incorrectly reported as withdrawn to the National Student Loan Data Systems (NSLDS). The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the College. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate and could affect student loan repayments.
Questioned Costs: None
Recommendation: The College should review its policy on enrollment reporting to NSLDS to ensure all status changes during the year are reported in a timely and accurate manner.
Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting.
Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.
Finding 2024-001: Eligibility-Pell Grant (Significant Deficiency)
Federal Program - Federal Pell Grant Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN - 84.063
Federal Award Year - June 30, 2024
Criteria: 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 (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student's enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts.
Condition/Context: For one student out of 40 tested, the student was selected for, and completed, verification prior to the College disbursing funds for the Fall 2023 term. As a result of that verification, the student's Expected Family Contribution (EFC) decreased and the College received a valid, corrected ISIR. However, the student's award package was not updated as a result of the decreased EFC. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: A corrected ISIR came in after verification was complete and the review and re-packaging process never occurred.
Effect: The student was not awarded the appropriate amount of Federal Pell Grant funds based on the student's lower, corrected EFC.
Questioned Costs: $400
Recommendation: We recommend that a step is added to the College's standard verification procedures to ensure that Federal Pell Grant awards are appropriately adjusted for any changes in EFC that are the result of a completed verification.
Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed away. This happened due to human error. We have a process in place to monitor corrected ISIR transactions to ensure that the EFC (SAI effective for award year 2024-25 and later) agrees with our documentation. The student record is then given to the director for final review and repackaging. We have added an additional step now whereby the Pell Grant administrator also reviews the output report for ISIR imports on a weekly basis.
Finding 2024-002: Enrollment Reporting (Significant Deficiency)
Federal Program - Federal Direct Student Loans, Federal Pell Grant Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN - 84.268, 84.063
Federal Award Year - June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition/Context: For 4 of the 25 students tested, their enrollment status was incorrectly reported as withdrawn to the National Student Loan Data Systems (NSLDS). The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the College. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate and could affect student loan repayments.
Questioned Costs: None
Recommendation: The College should review its policy on enrollment reporting to NSLDS to ensure all status changes during the year are reported in a timely and accurate manner.
Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting.
Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.
Finding 2024-002: Enrollment Reporting (Significant Deficiency)
Federal Program - Federal Direct Student Loans, Federal Pell Grant Program
Federal Agency - U.S. Department of Education
Pass-Through Entity - Not Applicable
ALN - 84.268, 84.063
Federal Award Year - June 30, 2024
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition/Context: For 4 of the 25 students tested, their enrollment status was incorrectly reported as withdrawn to the National Student Loan Data Systems (NSLDS). The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide.
Cause: An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the College. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate and could affect student loan repayments.
Questioned Costs: None
Recommendation: The College should review its policy on enrollment reporting to NSLDS to ensure all status changes during the year are reported in a timely and accurate manner.
Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting.
Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.