Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan
program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by institutions.
Institutions must review, update, and verify student enrollment statuses, program information, and effective
dates reported to NSLDS. Institutions are responsible for accurate reporting.
According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the
NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan
was intended”. Changes to status are required to be reported within 30 days of becoming aware of the
status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60
days.
Condition - A sample of students were selected from the population of all students who received federal
student financial aid during the year ended September 30, 2024. We obtained the student records and
tested compliance with federal regulations for the specific loans and grants.
For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported
within the 60-day reporting window after the status change was effective.
For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS.
Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were
not adequate.
Effect - Student status changes were not reported to NSLDS within the required timeframe.
Identification of Repeat Finding - Repeat finding of prior year finding 2023-002.
Recommendation - We recommend the College revise its processes for reporting student status changes
to NSLDS. The College should implement a process to review, update, and verify student enrollment
statuses that appear on the Enrollment Reporting roster files. We also recommend that management
implement controls to ensure reported changes are timely and correctly reported to the NSLDS.
Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding
error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected
subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected
information was submitted to the appropriate federal and state agencies in compliance with reporting
requirements.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007,
84.033, 84.063, and 84.268.
Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a
payment period or period of enrollment in which the recipient began attendance, the institution must
determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total
amount of Title IV assistance earned by the student is less than the amount that was disbursed to the
student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the
difference must be returned to the Title IV programs as outlined in this section and no additional
disbursements may be made to the student for the payment period or period of enrollment. If the amount
the student earned is greater than the amount disbursed, the difference between the amounts must be
treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)).
Condition - A sample of 40 students were selected from a population of all students that were withdrawn,
dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain
if returns of Title IV funds were properly calculated and timely processed.
For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated
the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4
calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted
in overcalculating the return of funds by the institution and undercalculating the return of funds by the
student that needed to be returned to the U.S. Department of Education (ED).
For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned
funds between the College and the student. As a result, the student’s portion of the returned funds was
either over- or under-reported, impacting both the student’s financial aid account and the College’s
compliance with federal requirements.
For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end
dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was
not performed when required, the College did not determine the amount of Title IV funds to be returned for
students who withdrew, as mandated by the U.S. Department of Education.
Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's
processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not
include sufficient verification steps to ensure accuracy.
Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of
Education.
Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure
ongoing compliance with federal requirements and to identify potential errors before they impact students
or the institution. We also recommend that management strengthens internal controls to ensure that the
correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This
should include system checks or automated tools to flag discrepancies.
Views of Responsible Officials - Management agrees with the finding.