Finding 2024-001: Enrollment Reporting - Material Weakness
Repeat Finding: 2023-001
ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct
loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035).
Institutions must review, update, and certify student enrollment statuses, program information, and
effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance
page of the NSLDS Professional Access (NSLDSFAP) website.
Condition: For one withdrawn student, the College erroneously reported the effective date of the
withdrawal. For one withdrawn student, there was no record found on NSLDS and the withdrawn
status was not reported. For two graduated students, the status was reported incorrectly and not
corrected in subsequent reporting files. For three students, the college did not report their status to
NSLDS within the 60 day threshold. The sample, which consisted of 25 students, was not a
statistically valid sample.
Cause: The College noted the discrepancies in reporting of the withdrawn students to be human
error. The College noted the inaccurate reporting of the students in the 5-year program and nonstandard
terms to be an issue with their reporting policy in place for this particular program and will
update the policy moving forward.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the
enrollment information reported by the schools. If an institution does not review, update, and verifystudent
enrollment statuses, effective dates of the enrollment status, and other information, then the
Title IV student loan records will be inaccurate, which impacts student loan repayments.
Questioned Costs: None.
Recommendation: It is recommended that the College review policies and procedures in place to
resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations.
Management Response: The College acknowledges and concurs with the finding. The College is in
the process of implementing changes to the student information systems and related process to
accommodate both the internal enrollment polices and required reporting statuses, and enhances
monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
Finding 2024-002: Eligibility - Satisfactory Academic Progress - Significant Deficiency
Repeat Finding: 2023-002
ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work
Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins
Loan Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: To begin and to continue to participate in any Title IV, the Higher Education Act of 1965
(HEA) program, an institution shall demonstrate to the Secretary that the institution is capable of
adequately administering that program under each of the standards established under 34 CFR
668.16. One of these standards states that for purposes of determining student eligibility for
assistance under a Title IV, HEA program, the institution must establish, publish, and apply
reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory
academic progress in his or her educational program.
Condition: Of the sixty students tested for eligibility, three students did not meet satisfactory academic
progress. The College was not able to provide the academic probation warning or Academic Action
Plan that was sent to these students in line with the College's policy. The sample was not a
statistically valid sample.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: If the College is not following their policies and procedures for determining student eligibility of
Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to
continue participating in the Title IV program.
Questioned Costs: None.
Recommendation: It is recommended that the school designate an employee within the financial aid
department to be responsible for monitoring academic progress and following the procedures stated
within the College's Academic Progress Policy when a student does not meet the minimum
standards.
Management Response: The College concurs with the finding and is in the process of implementing a
policy when satisfactory academic progress is run, students will be notified via mail or email of their
academic standing. Students who are suspended will have an opportunity to appeal their suspension.
If the appeal of suspension is approved, students will meet with their academic advisor to be placed
on an academic plan. The academic plan must be signed by both the student and advisor. The
academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will
be placed on the student's account until the signed academic plan is received. Once received, the
Office of Financial Aid will remove the hold so the student can be awarded.
Finding 2024-003: Return of Title IV Funds - Significant Deficiency
Repeat Finding: 2023-003
ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the
student earned as of the student's withdrawal date in accordance with Federal regulations and return
the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no
later than 45 days after the withdrawal date.
Condition: For one student selected for testing, the return of Title IV funding was not returned within
45 days of the date that it was determined that the student withdrew. For one student tested, the
semester parameters utilized by the College were inaccurate. The College originally determined that
the student had completed less than 60% of the semester and a refund was required. However, a
return was not required based on the student's actual semester length.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: The amounts refunded to the Department of Education may be incorrect. The College was
also in possession of funds belonging to the federal government longer than allowed.
Questioned Costs: $1,967
Context: There were a total of 19 students who withdrew during the year that received Title IV aid.
There was only one student that the College determined to require a return of Title IV funds. There
was also one student who was noted to not have a return of funds who did require a return of funds
based on testing, resulting in questioned costs. The sample was not considered statistically valid.
Recommendation: The College should modify its procedures for refunding awards to ensure proper
date computations, as well as disbursing refunds in a timely manner.
Management Response: Going forward, all students who withdraw from the College will be forwarded
to the financial aid team to review whether a student is still eligible for the full funding of the specific
semester in question or whether funding needs to be returned based on the withdrawal date. If it is
deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of
the student charges for that period and the Registrar will provide proof of the withdrawal date and the
financial aid team will determine the amount of funding that needs to be returned. Financial aid will
then complete the return through the student's account and notify the Controller and VP of Finance
and Administration to process the return to G5.
Finding 2024-004: Disbursements to Students - Significant Deficiency
ALN: 84.268 Federal Direct Loan Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: 34 CFR 668.164 requires that institutions must ensure that disbursements reported to the
Common Origination and Disbursement (COD) system accurately reflect the amounts posted to
students' accounts. Regular reconciliation between the COD system and institutional financial records
is required to identify and correct discrepancies, thereby maintaining compliance with federal
regulations. Failure to perform these reconciliations can lead to inaccurate financial reporting and
potential noncompliance with Title IV requirements.
Condition: Of the forty disbursements to students tested, one disbursement tested had a difference
when reconciling the student account statement to the COD system. The sample was not a
statistically valid sample.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: The potential exists that an error could occur in the financial records and not be detected
within a timely manner resulting in variances between the College's records and the Department of
Education records.
Questioned Costs: $494
Recommendation: The College should perform monthly reconciliations of the College’s financial
records compared to the Direct Loan system records on a timely basis and they should be reviewed
and approved by someone other than the original preparer who would be knowledgeable enough to
identify and correct all errors to ensure compliance with federal regulations.
Management Response: Management concurs with the finding and will reconcile the College’s
disbursement records with the federal COD system and correct all errors on a monthly basis.
Finding 2024-001: Enrollment Reporting - Material Weakness
Repeat Finding: 2023-001
ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct
loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035).
Institutions must review, update, and certify student enrollment statuses, program information, and
effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance
page of the NSLDS Professional Access (NSLDSFAP) website.
Condition: For one withdrawn student, the College erroneously reported the effective date of the
withdrawal. For one withdrawn student, there was no record found on NSLDS and the withdrawn
status was not reported. For two graduated students, the status was reported incorrectly and not
corrected in subsequent reporting files. For three students, the college did not report their status to
NSLDS within the 60 day threshold. The sample, which consisted of 25 students, was not a
statistically valid sample.
Cause: The College noted the discrepancies in reporting of the withdrawn students to be human
error. The College noted the inaccurate reporting of the students in the 5-year program and nonstandard
terms to be an issue with their reporting policy in place for this particular program and will
update the policy moving forward.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the
enrollment information reported by the schools. If an institution does not review, update, and verifystudent
enrollment statuses, effective dates of the enrollment status, and other information, then the
Title IV student loan records will be inaccurate, which impacts student loan repayments.
Questioned Costs: None.
Recommendation: It is recommended that the College review policies and procedures in place to
resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations.
Management Response: The College acknowledges and concurs with the finding. The College is in
the process of implementing changes to the student information systems and related process to
accommodate both the internal enrollment polices and required reporting statuses, and enhances
monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
Finding 2024-002: Eligibility - Satisfactory Academic Progress - Significant Deficiency
Repeat Finding: 2023-002
ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work
Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins
Loan Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: To begin and to continue to participate in any Title IV, the Higher Education Act of 1965
(HEA) program, an institution shall demonstrate to the Secretary that the institution is capable of
adequately administering that program under each of the standards established under 34 CFR
668.16. One of these standards states that for purposes of determining student eligibility for
assistance under a Title IV, HEA program, the institution must establish, publish, and apply
reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory
academic progress in his or her educational program.
Condition: Of the sixty students tested for eligibility, three students did not meet satisfactory academic
progress. The College was not able to provide the academic probation warning or Academic Action
Plan that was sent to these students in line with the College's policy. The sample was not a
statistically valid sample.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: If the College is not following their policies and procedures for determining student eligibility of
Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to
continue participating in the Title IV program.
Questioned Costs: None.
Recommendation: It is recommended that the school designate an employee within the financial aid
department to be responsible for monitoring academic progress and following the procedures stated
within the College's Academic Progress Policy when a student does not meet the minimum
standards.
Management Response: The College concurs with the finding and is in the process of implementing a
policy when satisfactory academic progress is run, students will be notified via mail or email of their
academic standing. Students who are suspended will have an opportunity to appeal their suspension.
If the appeal of suspension is approved, students will meet with their academic advisor to be placed
on an academic plan. The academic plan must be signed by both the student and advisor. The
academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will
be placed on the student's account until the signed academic plan is received. Once received, the
Office of Financial Aid will remove the hold so the student can be awarded.
Finding 2024-003: Return of Title IV Funds - Significant Deficiency
Repeat Finding: 2023-003
ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the
student earned as of the student's withdrawal date in accordance with Federal regulations and return
the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no
later than 45 days after the withdrawal date.
Condition: For one student selected for testing, the return of Title IV funding was not returned within
45 days of the date that it was determined that the student withdrew. For one student tested, the
semester parameters utilized by the College were inaccurate. The College originally determined that
the student had completed less than 60% of the semester and a refund was required. However, a
return was not required based on the student's actual semester length.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: The amounts refunded to the Department of Education may be incorrect. The College was
also in possession of funds belonging to the federal government longer than allowed.
Questioned Costs: $1,967
Context: There were a total of 19 students who withdrew during the year that received Title IV aid.
There was only one student that the College determined to require a return of Title IV funds. There
was also one student who was noted to not have a return of funds who did require a return of funds
based on testing, resulting in questioned costs. The sample was not considered statistically valid.
Recommendation: The College should modify its procedures for refunding awards to ensure proper
date computations, as well as disbursing refunds in a timely manner.
Management Response: Going forward, all students who withdraw from the College will be forwarded
to the financial aid team to review whether a student is still eligible for the full funding of the specific
semester in question or whether funding needs to be returned based on the withdrawal date. If it is
deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of
the student charges for that period and the Registrar will provide proof of the withdrawal date and the
financial aid team will determine the amount of funding that needs to be returned. Financial aid will
then complete the return through the student's account and notify the Controller and VP of Finance
and Administration to process the return to G5.
Finding 2024-004: Disbursements to Students - Significant Deficiency
ALN: 84.268 Federal Direct Loan Program
Award Year: July 1, 2023 - June 30, 2024
Federal Agency: U.S. Department of Education
Pass-Through Entity: Not applicable
Criteria: 34 CFR 668.164 requires that institutions must ensure that disbursements reported to the
Common Origination and Disbursement (COD) system accurately reflect the amounts posted to
students' accounts. Regular reconciliation between the COD system and institutional financial records
is required to identify and correct discrepancies, thereby maintaining compliance with federal
regulations. Failure to perform these reconciliations can lead to inaccurate financial reporting and
potential noncompliance with Title IV requirements.
Condition: Of the forty disbursements to students tested, one disbursement tested had a difference
when reconciling the student account statement to the COD system. The sample was not a
statistically valid sample.
Cause: The College had turnover in staffing within the financial aid department causing these
procedures to be missed.
Effect: The potential exists that an error could occur in the financial records and not be detected
within a timely manner resulting in variances between the College's records and the Department of
Education records.
Questioned Costs: $494
Recommendation: The College should perform monthly reconciliations of the College’s financial
records compared to the Direct Loan system records on a timely basis and they should be reviewed
and approved by someone other than the original preparer who would be knowledgeable enough to
identify and correct all errors to ensure compliance with federal regulations.
Management Response: Management concurs with the finding and will reconcile the College’s
disbursement records with the federal COD system and correct all errors on a monthly basis.