Criteria: Per 34 CFR 690.83, 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. Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement. Condition/context: Of the 27 students selected for Pell reporting testing, four students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement. Cause: Due to turnover within the Student Financial Aid Director position during the year, the students were not reported timely in the COD system. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-002. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary. Condition/context: The Student Financial Aid Program was unable to provide documentation for Direct Loan reconciliations that had been completed during the year. Cause: Due to turnover within the Student Financial Aid Director position, and due to ongoing systematic issues with accessing the COD system, the Student Financial Aid Office was unable to provide sufficient documentation that Direct Loan reconciliations were submitted to the COD system during the year. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, if not completed on a regular basis, the College is at risk of not meeting disbursement reporting and excess cash deadlines. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-003. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations and retain associated support. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.83, 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 in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary. Condition/context: Of the 17 students selected for testing: • One student’s withdrawn status was not reported to NSLDS. • One graduated student was not reported properly as such at the Campus Level. • Five students were not reported to NSLDS with an accurate withdrawal date. • Two students’ status changes were not reported within 60 days of the date of determination. • Two students’ program start dates were not reported accurately. Cause: The Student Financial Aid Office and Records and Registration do not have consistent controls in place to ensure the proper and timely reporting of student status changes. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-005. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred later than 45 days after the institution determines that the student withdrew. Condition/context: Of the 13 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew. Cause: The Student Financial Aid Office did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and return unearned Title IV aid to the U.S. Department of Education timely. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: Yes. See 2024-004. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.