Criteria
According to 34 CFR 668.22(j)(1):
Timeframe for the return of Title IV funds. 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.
According to 34 CFR 668.173(b):
Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if -
(1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew;
(2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew;
(3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, then informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or
(4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if -
(i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or
(ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.
Condition
Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 49-236 days.
Cause
The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days.
Effect
The College did not return two students' unearned Title IV funds within the required 45-day timeframe.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe.
Identification as a Repeat Finding, if applicable
This is a repeat finding from the year ended June 30, 2023.
Recommendation
The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required timeframe.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 668.22(j)(1):
Timeframe for the return of Title IV funds. 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.
According to 34 CFR 668.173(b):
Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if -
(1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew;
(2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew;
(3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, then informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or
(4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if -
(i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or
(ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.
Condition
Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 49-236 days.
Cause
The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days.
Effect
The College did not return two students' unearned Title IV funds within the required 45-day timeframe.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe.
Identification as a Repeat Finding, if applicable
This is a repeat finding from the year ended June 30, 2023.
Recommendation
The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required timeframe.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] 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; or
(ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment status to the National Student Loan Data System (“NSLDS”) correctly. Of the 40 students selected for testing, 3 students had status changes that were not reported to NSLDS within the required timeframe and 2 students had status changes that were not reported to NSLDS properly.
Cause
The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS properly and within the required timeframe.
Effect
The College did not report the student’s status change to NSLDS properly, which may impact the student’s loan grace periods.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe and 2 students, or 5% of our sample, had status changes that were not reported to NSLDS properly.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting timely and accurately and the consequences of late and inaccurate reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] 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; or
(ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment status to the National Student Loan Data System (“NSLDS”) correctly. Of the 40 students selected for testing, 3 students had status changes that were not reported to NSLDS within the required timeframe and 2 students had status changes that were not reported to NSLDS properly.
Cause
The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS properly and within the required timeframe.
Effect
The College did not report the student’s status change to NSLDS properly, which may impact the student’s loan grace periods.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe and 2 students, or 5% of our sample, had status changes that were not reported to NSLDS properly.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting timely and accurately and the consequences of late and inaccurate reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 668.22(j)(1):
Timeframe for the return of Title IV funds. 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.
According to 34 CFR 668.173(b):
Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if -
(1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew;
(2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew;
(3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, then informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or
(4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if -
(i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or
(ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.
Condition
Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 49-236 days.
Cause
The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days.
Effect
The College did not return two students' unearned Title IV funds within the required 45-day timeframe.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe.
Identification as a Repeat Finding, if applicable
This is a repeat finding from the year ended June 30, 2023.
Recommendation
The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required timeframe.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 668.22(j)(1):
Timeframe for the return of Title IV funds. 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.
According to 34 CFR 668.173(b):
Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if -
(1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew;
(2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew;
(3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, then informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or
(4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if -
(i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or
(ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.
Condition
Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 49-236 days.
Cause
The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days.
Effect
The College did not return two students' unearned Title IV funds within the required 45-day timeframe.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe.
Identification as a Repeat Finding, if applicable
This is a repeat finding from the year ended June 30, 2023.
Recommendation
The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required timeframe.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] 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; or
(ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment status to the National Student Loan Data System (“NSLDS”) correctly. Of the 40 students selected for testing, 3 students had status changes that were not reported to NSLDS within the required timeframe and 2 students had status changes that were not reported to NSLDS properly.
Cause
The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS properly and within the required timeframe.
Effect
The College did not report the student’s status change to NSLDS properly, which may impact the student’s loan grace periods.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe and 2 students, or 5% of our sample, had status changes that were not reported to NSLDS properly.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting timely and accurately and the consequences of late and inaccurate reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The College agrees with the finding.
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] 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; or
(ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment status to the National Student Loan Data System (“NSLDS”) correctly. Of the 40 students selected for testing, 3 students had status changes that were not reported to NSLDS within the required timeframe and 2 students had status changes that were not reported to NSLDS properly.
Cause
The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS properly and within the required timeframe.
Effect
The College did not report the student’s status change to NSLDS properly, which may impact the student’s loan grace periods.
Questioned Costs
Not applicable.
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe and 2 students, or 5% of our sample, had status changes that were not reported to NSLDS properly.
Identification as a Repeat Finding, if applicable
Not applicable.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting timely and accurately and the consequences of late and inaccurate reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The College agrees with the finding.