FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063, 84.007, 84.033
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of
their current academic period and is determined as having not earned 100 percent of their received Title
IV assistance, an institution must return the total amount of unearned Title IV assistance received from
withdrawn students.
Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial
Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as
possible, but no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution determined the
student withdrew or the date on the canceled check shows the check was endorsed more than 60 days
after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Condition and Context: A sample of 8 students who were recipients of Title IV funding and had
withdrawn during the year was selected for our testing procedures. Our sample was selected using a
random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31
unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring
term, which included the spring break within the total days used in the R2T4 calculation. Based on the
2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are
excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore,
34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the
payment period. The College did not perform the Title IV calculation within the College’s policy or within
Federal requirements, and therefore returned too much funding.
Questioned costs: None.
Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds.
For the 4 students we tested, there was no impact to the student, but instead the College received less
funding due to the over return.
Cause: The College’s policy was not adhered to and as such was the control was not operating as
intended.
Repeat finding: No.
Recommendation: We recommend the College ensure the policy is being followed which requires
scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in
the R2T4 calculation.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063, 84.007, 84.033
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of
their current academic period and is determined as having not earned 100 percent of their received Title
IV assistance, an institution must return the total amount of unearned Title IV assistance received from
withdrawn students.
Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial
Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as
possible, but no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution determined the
student withdrew or the date on the canceled check shows the check was endorsed more than 60 days
after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Condition and Context: A sample of 8 students who were recipients of Title IV funding and had
withdrawn during the year was selected for our testing procedures. Our sample was selected using a
random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31
unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring
term, which included the spring break within the total days used in the R2T4 calculation. Based on the
2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are
excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore,
34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the
payment period. The College did not perform the Title IV calculation within the College’s policy or within
Federal requirements, and therefore returned too much funding.
Questioned costs: None.
Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds.
For the 4 students we tested, there was no impact to the student, but instead the College received less
funding due to the over return.
Cause: The College’s policy was not adhered to and as such was the control was not operating as
intended.
Repeat finding: No.
Recommendation: We recommend the College ensure the policy is being followed which requires
scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in
the R2T4 calculation.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063, 84.007, 84.033
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of
their current academic period and is determined as having not earned 100 percent of their received Title
IV assistance, an institution must return the total amount of unearned Title IV assistance received from
withdrawn students.
Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial
Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as
possible, but no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution determined the
student withdrew or the date on the canceled check shows the check was endorsed more than 60 days
after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Condition and Context: A sample of 8 students who were recipients of Title IV funding and had
withdrawn during the year was selected for our testing procedures. Our sample was selected using a
random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31
unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring
term, which included the spring break within the total days used in the R2T4 calculation. Based on the
2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are
excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore,
34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the
payment period. The College did not perform the Title IV calculation within the College’s policy or within
Federal requirements, and therefore returned too much funding.
Questioned costs: None.
Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds.
For the 4 students we tested, there was no impact to the student, but instead the College received less
funding due to the over return.
Cause: The College’s policy was not adhered to and as such was the control was not operating as
intended.
Repeat finding: No.
Recommendation: We recommend the College ensure the policy is being followed which requires
scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in
the R2T4 calculation.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-003 – Enrollment Reporting
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with
deadline dates established by the Secretary, through publication in the Federal Register, other reports
and information the Secretary requires and shall comply with the procedures the Secretary finds
necessary to ensure that the reports are correct.
The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized
database for students’ enrollment information. It is the College’s responsibility to update this information
timely and accurately.
The College determines how often it receives the Enrollment Reporting roster file with the default set at
every 60 days.
Condition and context: 2 submissions of withdrawal were reported late and not identified prior to
submission. 20 students were sampled using a random sampling methodology, from a population of 42
withdrawals, and 244 graduates.
Questioned costs: None.
Effect: This information is utilized by the Department of Education, the Federal Direct Loan program,
lenders, and other institutions to determine in-school status. However, American Samoa Community
College doesn’t participate in loan programs, which limits the effect of non-compliance.
Cause: In fiscal year 2024, the College implemented many new controls which were communicated in the
previous corrective action in the preceding year. One control that was not implemented until May 2024
was the control related to the review by the Financial Aid Manager of the prepared Roster File prior to
submission. We noted that the control was operating as designed post implementation. The College’s
policy was not adhered to between October 2023 and May 2024 and as such was the control was not
operating as intended during that period.
Repeat finding: Yes.
Recommendation: We recommend that the College ensure the policy is being followed which requires a
review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we
recommend the College retain documentation reflecting all formal reviews of the roster. This
Recommendation: We recommend that the College ensure the policy is being followed which requires a
review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we
recommend the College retain documentation reflecting all formal reviews of the roster. This
recommendation was made in the prior year and correction occurred during the current fiscal year; we
noted that the control was operating as designed post implementation in May 2024.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063, 84.007, 84.033
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of
their current academic period and is determined as having not earned 100 percent of their received Title
IV assistance, an institution must return the total amount of unearned Title IV assistance received from
withdrawn students.
Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial
Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as
possible, but no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution determined the
student withdrew or the date on the canceled check shows the check was endorsed more than 60 days
after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Condition and Context: A sample of 8 students who were recipients of Title IV funding and had
withdrawn during the year was selected for our testing procedures. Our sample was selected using a
random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31
unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring
term, which included the spring break within the total days used in the R2T4 calculation. Based on the
2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are
excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore,
34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the
payment period. The College did not perform the Title IV calculation within the College’s policy or within
Federal requirements, and therefore returned too much funding.
Questioned costs: None.
Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds.
For the 4 students we tested, there was no impact to the student, but instead the College received less
funding due to the over return.
Cause: The College’s policy was not adhered to and as such was the control was not operating as
intended.
Repeat finding: No.
Recommendation: We recommend the College ensure the policy is being followed which requires
scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in
the R2T4 calculation.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063, 84.007, 84.033
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of
their current academic period and is determined as having not earned 100 percent of their received Title
IV assistance, an institution must return the total amount of unearned Title IV assistance received from
withdrawn students.
Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial
Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as
possible, but no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution determined the
student withdrew or the date on the canceled check shows the check was endorsed more than 60 days
after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Condition and Context: A sample of 8 students who were recipients of Title IV funding and had
withdrawn during the year was selected for our testing procedures. Our sample was selected using a
random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31
unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring
term, which included the spring break within the total days used in the R2T4 calculation. Based on the
2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are
excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore,
34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the
payment period. The College did not perform the Title IV calculation within the College’s policy or within
Federal requirements, and therefore returned too much funding.
Questioned costs: None.
Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds.
For the 4 students we tested, there was no impact to the student, but instead the College received less
funding due to the over return.
Cause: The College’s policy was not adhered to and as such was the control was not operating as
intended.
Repeat finding: No.
Recommendation: We recommend the College ensure the policy is being followed which requires
scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in
the R2T4 calculation.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063, 84.007, 84.033
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of
their current academic period and is determined as having not earned 100 percent of their received Title
IV assistance, an institution must return the total amount of unearned Title IV assistance received from
withdrawn students.
Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial
Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as
possible, but no later than 45 days after the date the institution determines that the student withdrew.
Returns by check are late if the check is issued more than 45 days after the institution determined the
student withdrew or the date on the canceled check shows the check was endorsed more than 60 days
after the date the institution determined that the student withdrew (34 CFR 668.173(b)).
Condition and Context: A sample of 8 students who were recipients of Title IV funding and had
withdrawn during the year was selected for our testing procedures. Our sample was selected using a
random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31
unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring
term, which included the spring break within the total days used in the R2T4 calculation. Based on the
2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are
excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore,
34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the
payment period. The College did not perform the Title IV calculation within the College’s policy or within
Federal requirements, and therefore returned too much funding.
Questioned costs: None.
Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds.
For the 4 students we tested, there was no impact to the student, but instead the College received less
funding due to the over return.
Cause: The College’s policy was not adhered to and as such was the control was not operating as
intended.
Repeat finding: No.
Recommendation: We recommend the College ensure the policy is being followed which requires
scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in
the R2T4 calculation.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs
FINDING 2024-003 – Enrollment Reporting
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.063
Federal Program Name: Federal Pell Grant Program
Award Year: 2023-24
Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with
deadline dates established by the Secretary, through publication in the Federal Register, other reports
and information the Secretary requires and shall comply with the procedures the Secretary finds
necessary to ensure that the reports are correct.
The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized
database for students’ enrollment information. It is the College’s responsibility to update this information
timely and accurately.
The College determines how often it receives the Enrollment Reporting roster file with the default set at
every 60 days.
Condition and context: 2 submissions of withdrawal were reported late and not identified prior to
submission. 20 students were sampled using a random sampling methodology, from a population of 42
withdrawals, and 244 graduates.
Questioned costs: None.
Effect: This information is utilized by the Department of Education, the Federal Direct Loan program,
lenders, and other institutions to determine in-school status. However, American Samoa Community
College doesn’t participate in loan programs, which limits the effect of non-compliance.
Cause: In fiscal year 2024, the College implemented many new controls which were communicated in the
previous corrective action in the preceding year. One control that was not implemented until May 2024
was the control related to the review by the Financial Aid Manager of the prepared Roster File prior to
submission. We noted that the control was operating as designed post implementation. The College’s
policy was not adhered to between October 2023 and May 2024 and as such was the control was not
operating as intended during that period.
Repeat finding: Yes.
Recommendation: We recommend that the College ensure the policy is being followed which requires a
review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we
recommend the College retain documentation reflecting all formal reviews of the roster. This
Recommendation: We recommend that the College ensure the policy is being followed which requires a
review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we
recommend the College retain documentation reflecting all formal reviews of the roster. This
recommendation was made in the prior year and correction occurred during the current fiscal year; we
noted that the control was operating as designed post implementation in May 2024.
Views of responsible officials and planned corrective actions:
Contact Person(s):
Shanell Tauiliili, Financial Aid Officer
Dr. Emilia Le' i, Dean of Student Services
Letupu Moananu, Vice President of Academics, Community, and Student Affairs