U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.
U.S. Department of Education
Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster
(significant deficiency)
Statement of Condition: From our testing sample of ten (10) students, we found six (6) instances where the
calculation of the students’ percentages of completion during the payment period were computed incorrectly
due to breaks of at least five (5) consecutive days being incorrectly computed in the calculation of the number
of days in the payment period. We also found four (4) instances where the Title IV funds were not returned
timely. We also found three (3) instances where changes in student status due to withdrawal were not
reported timely.
Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, the
number of days in the payment period should exclude any breaks of at least five (5) consecutive days where
no coursework was taking place. Also in accordance with 34 CFR 668.22, Treatment of Title IV Fund When
a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that
return calculations can be performed and any refunds can be made within forty-five (45) days after the date of
the school’s determination that the student has withdrawn.
39
Also in accordance with 34 CFR, Treatment of Title IV Funds When a Student Withdrawals, any changes to a
student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a
roster file is expected within that time frame.
Effect of Condition: We found six (6) instances where the calculation of the students’ percentages of
completion during the semester were computed incorrectly due to breaks of at least five (5) consecutive days
being incorrectly computed in the calculation of the number of days in the semester. We also found four (4)
instances where the Title IV funds were not returned timely. We also found three (3) instances where changes
in student status was not reported timely.
Cause of Condition: The College implemented a new system in the current year which resulted in errors in
the number of days in the payment period. The College does not consistently follow its policies and
procedures related to withdrawals.
Recommendation: We recommend the College follow its policies and procedures to address these issues.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement this
recommendation immediately.
Statement of Condition: From our testing sample of twenty-five (25) students, we found twenty-two (22)
instances where notices of federal direct loans being credited to a student’s account could not be vouched.
Criteria: In accordance with Volume 4 Chapter 2 of the Federal Student Aid Handbook, the school must
notify the borrower in writing within 30 days of funds being credited to the account: 1) the anticipated date
and amount of disbursement, 2) the right to cancel, and 3) the deadlines to notify the school if they wish to
cancel. In accordance with Volume 2 Chapter 7 of the Federal Student Aid Handbook, a school must keep
comprehensive, accurate program and fiscal records related to its use of FSA Funds. Student records
should be retained to “show a clear audit trail for FSA program expenditures.”
Effect of Condition: We found twenty-two (22) instances where borrower notifications were not retained.
Cause of Condition: The College implemented a new system in the current year.
Recommendation: We recommend the College develop policies and procedures to address this issue.
Management’s Response: Management agrees and will submit a Corrective Action Plan to implement
these recommendations immediately.