Enrollment Reporting to NSLDS Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 83 students tested, 35 students were not reported accurately to NSLDS. Twenty-six of these students showed "No Record Found," and the remaining 9 students still appeared enrolled after withdrawing/graduating in the Fall 2023 term.
Cause: Timely reconciliations of enrollment statuses were not completed throughout the year.
Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: 2023-007
Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn or graduated in NSLDS in a timely manner. We also recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly to ensure any students appearing as "No Record Found" are updated.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2024-003 Late Return of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid.
Criteria: 34 CFR 668.22
Questioned Costs: $2,817
Context: Out of 26 students tested for timely return of Title IV funding, 2 students who withdrew before the 60% mark of the term did not have an R2T4 completed. This resulted in $2,817 of unsubsidized loans that need to be returned to the Department of Education.
Cause: This was an oversight by the College.
Effect: Returns of federal funding were not made.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the College review all students with zero credits in a term at the end of the term to determine if they unofficially withdrew and if a return was necessary.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid.
Criteria: 34 CFR 685.200(a)
Questioned Costs: $7,568
Context: Out of 60 students, 3 students were not awarded aid appropriately based on need analysis. The first student received $3,000 in unsubsidized loans when they had additional subsidized loan eligibility to maximize before taking out unsubsidized loans. The second student was awarded $4,500 in subsidized loans in excess of need that should have been awarded as additional unsubsidized loans. The last student was over-awarded $68 in subsidized loans due to being over the aggregate subsidized loan limit.
Cause: These errors were an oversight by the College.
Effect: Incorrect allocation of subsidized loans versus unsubsidized loans affects the interest amount incurred by the student and could impact future loan eligibility. Additionally, students received subsidized federal aid for which they were not eligible.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend that the College set up reports in the student information system to periodically check for over or under awarding of need based federal aid. We also recommend that the student information system have notifications when updated ISIRs are received to review need analysis and update awarding as needed.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: As required under 34 CFR 668.56, for students who are flagged for verification, the College is required to obtain underlying tax and other information to verify that amounts are properly reported on the ISIR and correct the ISIR if there are discrepancies.
Criteria: 34 CFR 668.56
Questioned Costs: $5,500
Context: There was one student out of a sample of 25 selected for verification for which the College was not able to locate underlying tax support or number in college/number in family as provided by the student and/or parent.
Cause: Due to turnover and staffing challenges in the financial aid office, the support for this student was unable to be located.
Effect: Need based aid is impacted directly by the results of verification.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the College periodically review verification completed for students with need-based aid to ensure all required documentation is properly maintained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 83 students tested, 35 students were not reported accurately to NSLDS. Twenty-six of these students showed "No Record Found," and the remaining 9 students still appeared enrolled after withdrawing/graduating in the Fall 2023 term.
Cause: Timely reconciliations of enrollment statuses were not completed throughout the year.
Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: 2023-007
Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn or graduated in NSLDS in a timely manner. We also recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly to ensure any students appearing as "No Record Found" are updated.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Students were not always awarded the proper Pell Grant based on their enrollment level.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $0
Context: Out of 36 students tested for proper Pell Grant awarding based on enrollment level, there were 3 students who were under-awarded Pell Grant for the Summer 2024 term.
Cause: These errors were an oversight by the College.
Effect: Pell Grant was not awarded correctly based on enrollment.
Identification as repeat finding, if applicable: 2023-005, 2022-003
Recommendation: We recommend that the College review summer Pell Grant disbursements to ensure they reflect the student’s summer enrollment.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
USDA Community Facilities Loan Reserve Accounts Significant Deficiency
U.S. DEPARTMENT OF AGRICULTURE
ALN #: 10.766 Community Facilities Loans and Grants Cluster
Federal Award Identification #: 0000009560402CFL, 0000009560403CFL, CPAP000000010077, GLSX0002562746, 0000008718001CFL
Condition: Under multiple USDA Community Facilities loan agreements, the College is required to administer a loan reserve account in which monthly deposits are to be made for the first 10 years of the loan or until the loan minimum reserve amount is obtained.
Criteria: 37 CFR 1942.17(i)
Questioned Costs: $0
Context: The College was not properly administering the loan reserves as outlined in their USDA loan agreements.
Cause: Due to changes in management since the loans originated, there was a lack of oversight of the continuing loan reserve requirements across the various loan agreements.
Effect: The College did not make reserve contributions as required during the fiscal year ending June 30, 2024.
Identification as repeat finding, if applicable: 2023-004, 2022-002
Recommendation: We recommend the College work with their USDA loan representative to understand their USDA loan reserve requirements for all active and future loan agreements. Additionally, the College should establish the minimum reserve funds that have not been established as of June 30, 2024, and make monthly payments to the reserve account, as outlined in their loan agreements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 83 students tested, 35 students were not reported accurately to NSLDS. Twenty-six of these students showed "No Record Found," and the remaining 9 students still appeared enrolled after withdrawing/graduating in the Fall 2023 term.
Cause: Timely reconciliations of enrollment statuses were not completed throughout the year.
Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: 2023-007
Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn or graduated in NSLDS in a timely manner. We also recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly to ensure any students appearing as "No Record Found" are updated.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2024-003 Late Return of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid.
Criteria: 34 CFR 668.22
Questioned Costs: $2,817
Context: Out of 26 students tested for timely return of Title IV funding, 2 students who withdrew before the 60% mark of the term did not have an R2T4 completed. This resulted in $2,817 of unsubsidized loans that need to be returned to the Department of Education.
Cause: This was an oversight by the College.
Effect: Returns of federal funding were not made.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend the College review all students with zero credits in a term at the end of the term to determine if they unofficially withdrew and if a return was necessary.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid.
Criteria: 34 CFR 685.200(a)
Questioned Costs: $7,568
Context: Out of 60 students, 3 students were not awarded aid appropriately based on need analysis. The first student received $3,000 in unsubsidized loans when they had additional subsidized loan eligibility to maximize before taking out unsubsidized loans. The second student was awarded $4,500 in subsidized loans in excess of need that should have been awarded as additional unsubsidized loans. The last student was over-awarded $68 in subsidized loans due to being over the aggregate subsidized loan limit.
Cause: These errors were an oversight by the College.
Effect: Incorrect allocation of subsidized loans versus unsubsidized loans affects the interest amount incurred by the student and could impact future loan eligibility. Additionally, students received subsidized federal aid for which they were not eligible.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend that the College set up reports in the student information system to periodically check for over or under awarding of need based federal aid. We also recommend that the student information system have notifications when updated ISIRs are received to review need analysis and update awarding as needed.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Verification DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2023-2024 Award Year
Condition: As required under 34 CFR 668.56, for students who are flagged for verification, the College is required to obtain underlying tax and other information to verify that amounts are properly reported on the ISIR and correct the ISIR if there are discrepancies.
Criteria: 34 CFR 668.56
Questioned Costs: $5,500
Context: There was one student out of a sample of 25 selected for verification for which the College was not able to locate underlying tax support or number in college/number in family as provided by the student and/or parent.
Cause: Due to turnover and staffing challenges in the financial aid office, the support for this student was unable to be located.
Effect: Need based aid is impacted directly by the results of verification.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We recommend the College periodically review verification completed for students with need-based aid to ensure all required documentation is properly maintained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 83 students tested, 35 students were not reported accurately to NSLDS. Twenty-six of these students showed "No Record Found," and the remaining 9 students still appeared enrolled after withdrawing/graduating in the Fall 2023 term.
Cause: Timely reconciliations of enrollment statuses were not completed throughout the year.
Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: 2023-007
Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn or graduated in NSLDS in a timely manner. We also recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly to ensure any students appearing as "No Record Found" are updated.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Students were not always awarded the proper Pell Grant based on their enrollment level.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $0
Context: Out of 36 students tested for proper Pell Grant awarding based on enrollment level, there were 3 students who were under-awarded Pell Grant for the Summer 2024 term.
Cause: These errors were an oversight by the College.
Effect: Pell Grant was not awarded correctly based on enrollment.
Identification as repeat finding, if applicable: 2023-005, 2022-003
Recommendation: We recommend that the College review summer Pell Grant disbursements to ensure they reflect the student’s summer enrollment.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
USDA Community Facilities Loan Reserve Accounts Significant Deficiency
U.S. DEPARTMENT OF AGRICULTURE
ALN #: 10.766 Community Facilities Loans and Grants Cluster
Federal Award Identification #: 0000009560402CFL, 0000009560403CFL, CPAP000000010077, GLSX0002562746, 0000008718001CFL
Condition: Under multiple USDA Community Facilities loan agreements, the College is required to administer a loan reserve account in which monthly deposits are to be made for the first 10 years of the loan or until the loan minimum reserve amount is obtained.
Criteria: 37 CFR 1942.17(i)
Questioned Costs: $0
Context: The College was not properly administering the loan reserves as outlined in their USDA loan agreements.
Cause: Due to changes in management since the loans originated, there was a lack of oversight of the continuing loan reserve requirements across the various loan agreements.
Effect: The College did not make reserve contributions as required during the fiscal year ending June 30, 2024.
Identification as repeat finding, if applicable: 2023-004, 2022-002
Recommendation: We recommend the College work with their USDA loan representative to understand their USDA loan reserve requirements for all active and future loan agreements. Additionally, the College should establish the minimum reserve funds that have not been established as of June 30, 2024, and make monthly payments to the reserve account, as outlined in their loan agreements.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.