Audit 376312

Finding 2025-001 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: E. Eligibility - Cost of Attendance - For Title IV programs, the cost of attendance is generally the sum of the following: tuition and fees; an allowance for books, course materials, supplies, equipment, transportation, and miscellaneous personal expenses; an allowance for food and housing; when applicable, allowances for costs for dependent care; cost of obtaining a license, certification, or a first professional credential; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for Federal student loans (34 CFR 668.43). Condition: For 5 students selected for testing, the student’s estimated cost of attendance was not properly calculated. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with requirements for calculating cost of attendance. Questioned Costs: $0 Context: 5 out of 25 students selected for testing. Identification of Repeat Finding: There were no similar findings identified during the prior year. Recommendation: We recommend the College enhance its procedures over cost of attendance to ensure it is calculated correctly. Views of Responsible Officials: Management agrees with the finding that the estimated Cost of Attendance (COA) for the summer term was calculated incorrectly for five students. Because the summer term includes multiple sessions, the COA multi-step programming process in PowerFAIDS, the College’s financial aid management software, including the review of COA selection metrics, are manual. In April 2025, the College migrated its ERP software and PowerFAIDS to cloud-based platforms. This transaction required significant time from Office of Financial Aid (OFA) staff to test system functionality and validate migrated data to ensure a smooth go-live. As these efforts coincided with summer COA programming, the capacity for thorough review and comprehensive functional testing of summer COA setup was reduced. Going forward, the OFA will assign a staff member, separate from the individual handling COA programming, to review the COA selection metrics. In addition, the OFA will evaluate the potential of automating COA programming processes.

Finding 2025-002 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Notification of Disbursements - When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. Condition: For 1 student selected for testing, a disbursement notification was not sent to the student or parent within the required timeframe of 30 days. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with the requirements for notifying students or parents of the disbursement of federal loan funds to their account. Questioned Costs: $0 Context: 1 out of 25 students selected for testing. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College notify students or parents within the 30 day period. Views of Responsible Officials: Management acknowledges that for one student, the required federal direct loan disbursement notification was not sent within the required timeframe. After the parent’s PLUS loan was denied in April 2025, the student was offered an additional unsubsidized loan, which was accepted on 5/7/2025. The manually generated notification for the 5/8/2025 disbursement was inadvertently missed being sent out. We believe this oversight was an isolated incident due to the OFA’s unusually demanding April/May as noted in the previous finding. To mitigate this issue going forward, the OFA will remove the need for manual intervention by implementing an automated notification process utilizing the built-in scheduler functionality in PowerFAIDS.

Finding 2025-003 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: For 1 student selected for testing, certain key elements at the Program-Level were not correctly reported to the NSLDS. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with the requirements of Program-Level enrollment reporting. Questioned Costs: $0 Context: 1 out of 25 students selected for testing. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Management agrees with the finding that one student’s Program Begin Date was incorrectly reported to NSLDS. For this new student, the Program Begin Date was reported as 5/14/2021, the date the new student transitioned from admissions to registration, rather than the actual first day of the academic term in which the student began enrollment in the program, as required by Part 5 of the 2025 Compliance Supplement. Beginning with the 2020 OMB Compliance Supplement, enrollment reporting requirements were expanded to include additional compliance data elements for NSLDS. During the 2020-2021 award year, the National Student Clearinghouse (NSC), the College’s third-party servicer for enrollment reporting, encountered program level data integrity issues. In response, new warning codes were introduced in December 2021, including WC 1811 Series, which addresses mismatch flags in Program Begin Date. In this case, however, no warning flag was triggered for the student. The Registrar Office will follow up with NSC to identify why the warning flag did not trigger. Moving forward, Registrar Office staff will review enrollment reporting files to verify that each student’s Program Begin Date reflects the first day of the term in which the program enrollment began, unless the student’s enrollment in the program was on an earlier date.