Audit 350321

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program Department of Education July 1, 2023 – June 30, 2024 Institutions must report student disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. During our testwork over 40 students who received Pell Grant funds, we identified the following students in which the College did not accurately and timely report the disbursement to COD.• 14 students did not have their disbursement information submitted within 15 calendar days to the COD. • 20 students’ information were not accurately provided to the COD. The College’s control failed in detecting that untimely and inaccurate information was reported to COD. Systemic. None noted. The sample was not intended to be, and was not, a statistically valid sample. Yes, a similar finding was noted in the prior year. We recommend that the College enhance its internal controls to ensure all Pell disbursements are reported accurately and timely to COD. The College concurs with this finding as stated. We will modify internal controls to ensure accurate and timely reporting of student disbursement information to COD.

Student Financial Assistance Cluster 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Department of Education July 1, 2023 – June 30, 2024 Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: 2 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. 16 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe.Systemic. The College’s control failed in detecting that untimely information was reported to NSLDS. None noted. The sample was not intended to be, and was not, a statistically valid sample. Yes, a similar finding was noted in the prior year. We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. The College concurs with this finding as stated. We will modify internal controls to ensure accurate and timely reporting of student status changes to the National Student Loan Data System (NSLDS).

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program Department of Education July 1, 2023 – June 30, 2024 Institutions must report student disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. During our testwork over 40 students who received Pell Grant funds, we identified the following students in which the College did not accurately and timely report the disbursement to COD.• 14 students did not have their disbursement information submitted within 15 calendar days to the COD. • 20 students’ information were not accurately provided to the COD. The College’s control failed in detecting that untimely and inaccurate information was reported to COD. Systemic. None noted. The sample was not intended to be, and was not, a statistically valid sample. Yes, a similar finding was noted in the prior year. We recommend that the College enhance its internal controls to ensure all Pell disbursements are reported accurately and timely to COD. The College concurs with this finding as stated. We will modify internal controls to ensure accurate and timely reporting of student disbursement information to COD.

Student Financial Assistance Cluster 84.038 Federal Perkins Loan Program and 84.268 Federal Direct Student Loans Program Department of Education July 1, 2023 – June 30, 2024 Per 34 CFR 685.309, institutions with direct loan programs must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file, and report accurate Campus-Level and Program-Level Enrollment Data separately at least every 60 days or within 60 days of the student's status change. This is for the purpose of providing complete and accurate data to lenders regarding enrollment status so they may properly determine when repayment of the loans should begin. During our Enrollment Reporting testwork over 40 students that received loans under Title IV and ceased to be enrolled on at least a halftime basis, went on leave of absence, graduated, or withdrew, we noted the following: 2 student enrollment status change effective dates reported to NSLDS at the Program Level did not agree with Whittier’s internal records or to the Campus Level report. 16 student enrollment status changes were not reported to NSLDS within the required 60-day timeframe.Systemic. The College’s control failed in detecting that untimely information was reported to NSLDS. None noted. The sample was not intended to be, and was not, a statistically valid sample. Yes, a similar finding was noted in the prior year. We recommend that the College enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. The College concurs with this finding as stated. We will modify internal controls to ensure accurate and timely reporting of student status changes to the National Student Loan Data System (NSLDS).