Audit 351935

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033 Award year: 2024 Criteria According to the 2023-2024 Federal Student Aid Handbook, Volume 6 The Campus-Based Programs Chapter 2: In general, students are not permitted to work in Federal Work-Study (“FWS”) positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Condition Federal regulations state that students are not permitted to work in Federal Work-Study positions during scheduled class times. During our testing, we noted 1 student, out of a sample of 2, worked for a Federal Work-Study program during scheduled class time. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student timesheets related to FWS funds. Effect Franklin Cummings Tech approved FWS funds for time worked during scheduled class times. Questioned Costs $23 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 2 students selected for testing, 1 student, or 50% of our sample, had FWS funds approved for hours worked during scheduled class times. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the approval of hours worked for the Federal Work-Study Program to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 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, that 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. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 6, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 7 days. Cause Franklin Cummings Tech 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 Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 6 students selected for testing, 1 student, or 16.7% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its 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 time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 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, that 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. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 6, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 7 days. Cause Franklin Cummings Tech 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 Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 6 students selected for testing, 1 student, or 16.7% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its 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 time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless 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. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: 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 Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 3 out of 14 students were reported with an incorrect effective date. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 3 students, or 21.4% of our sample, did not report the correct effective dates. Identification as a Repeat Finding, if applicable See finding 2023-004 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless 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. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: 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 Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 3 out of 14 students were reported with an incorrect effective date. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 3 students, or 21.4% of our sample, did not report the correct effective dates. Identification as a Repeat Finding, if applicable See finding 2023-004 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033 Award year: 2024 Criteria According to the 2023-2024 Federal Student Aid Handbook, Volume 6 The Campus-Based Programs Chapter 2: In general, students are not permitted to work in Federal Work-Study (“FWS”) positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Condition Federal regulations state that students are not permitted to work in Federal Work-Study positions during scheduled class times. During our testing, we noted 1 student, out of a sample of 2, worked for a Federal Work-Study program during scheduled class time. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student timesheets related to FWS funds. Effect Franklin Cummings Tech approved FWS funds for time worked during scheduled class times. Questioned Costs $23 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 2 students selected for testing, 1 student, or 50% of our sample, had FWS funds approved for hours worked during scheduled class times. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the approval of hours worked for the Federal Work-Study Program to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 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, that 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. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 6, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 7 days. Cause Franklin Cummings Tech 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 Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 6 students selected for testing, 1 student, or 16.7% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its 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 time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 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, that 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. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 6, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 7 days. Cause Franklin Cummings Tech 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 Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 6 students selected for testing, 1 student, or 16.7% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its 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 time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless 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. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: 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 Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 3 out of 14 students were reported with an incorrect effective date. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 3 students, or 21.4% of our sample, did not report the correct effective dates. Identification as a Repeat Finding, if applicable See finding 2023-004 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless 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. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: 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 Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 3 out of 14 students were reported with an incorrect effective date. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 3 students, or 21.4% of our sample, did not report the correct effective dates. Identification as a Repeat Finding, if applicable See finding 2023-004 included in the summary schedule of prior year findings. Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.