2025-001 Direct Programs – Department of Education ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provisions – Return to Title IV Material Weakness in Internal Controls Over Compliance Criteria: 34 CFR section 668.22(e) states that if a student withdraws from classes and has received student financial aid, the amount of unearned Title IV assistance must be calculated and returned to the Department of Education (DOE) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition: During our review of the return of Title IV funds, there were eleven instances out of thirty in which the Title IV funds to be returned were not calculated and returned if required within the 45-day maximum timeframe allowed. The R2T4 calculations for fall 2024 were not performed until February 2025. Cause: The College’s existing control procedures to ensure the return of Title IV funds is calculated and the funds returned within 45 days were not functioning. Effect: The funds required to be returned were not calculated timely and were not remitted to the DOE timely. Questioned Costs: None reported Sampling: A nonstatistical sample of 30 returns out of 149 returns were selected for testing. Repeat Finding from Prior Years: No Recommendation: The College should implement a control process that regularly reviews all withdrawn students that received Title IV awards and ensure the return of Title IV funds is calculated timely, and the amount calculated is appropriately remitted back to the DOE in a timely manner. Views of Responsible Officials: The Director of Financial Aid agrees with the finding.
2025-002 Direct Programs – Department of Education ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Cash Management & Reporting Material Weakness in Internal Controls Over Compliance Criteria: 34 CFR 685.300(b)(5). Electronic Announcements DL-22-07 and GENERAL-22-86 explain that a school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. The school is required to account for any differences by reconciling the DOE’s records (School Account Statements) with the school’s financial and business records. Condition: During our review of the reconciliation process, we noted that only the month of January was reconciled as required by the DOE. Cause: The College’s existing control procedures to ensure reconciliation was occurring monthly were not functioning. Effect: The College did not reconcile the funds received with actual disbursement records the College submitted to COD. As a result, any difference between DOE’s records and the College’s financial and business records could go undetected and uncorrected. Questioned Costs: None reported Sampling: No sampling was done as the reconciliation process for the year was not performed for any month other than January 2025. Repeat Finding from Prior Years: No Recommendation: The College should implement a control process that requires monthly reconciliation of the funds received with actual disbursement records the College submitted to COD. Views of Responsible Officials: The Director of Financial Aid agrees with the finding.
2025-003 Direct Programs – Department of Education ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement to or on Behalf of Students Material Weakness in Internal Controls Over Compliance Criteria: According to the Student Financial Aid Handbook, when calculating a student’s unmet need, non-FSA sources of aid need to be taken into consideration. When classifying non-FSA sources of aid, if a student receives the award because of postsecondary enrollment (for example, a scholarship from a local social club that requires a student to be attending a postsecondary school), it counts as Other Financial Assistance (OFA). The College must make a reasonable attempt to determine what OFA the student will receive and apply as the total consideration for the student's aid package. Condition: During our review of the calculation of student disbursements, we noted a student whose awards exceeded the unmet need. This over award was created by OFA that was received in the form of non-Title IV scholarships. Cause: The College’s existing control procedures to ensure that students receiving OFA were not over awarded were not functioning properly. Effect: The College did not take OFA into consideration when disbursing Title IV awards. As a result, a student received awards exceeding the unmet need. Questioned Costs: $1,663 Sampling: A nonstatistical sample of 60 disbursements out of 6,700 disbursements were selected for testing. Repeat Finding from Prior Years: No Recommendation: The College should implement a control process to ensure OFA are properly identified and taken into consideration when creating a student’s financial aid package. The College should consider whether or not the Department of Education needs to be made whole. Views of Responsible Officials: The Director of Financial Aid agrees with the finding.
2025-004 Direct Programs – Department of Education ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement to or on Behalf of Students Significant Deficiency in Internal Controls Over Compliance Criteria: Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Additionally, when direct loans 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; 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 (a minimum of 14 or 30 days depending on confirmation process). 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. Condition: During our review of the direct loans disbursed to students, we noted notifications were not sent to students and parents as required. Cause: The College’s existing control procedures to ensure proper notification to students and parents were not functioning properly. Effect: The College did not send the required notifications to students and parents receiving loans under Title IV. Questioned Costs: None Sampling: A nonstatistical sample of 60 students out of 1,696 students were selected for testing. Within this sample of 60 there were 13 students receiving loans. Total population of students receiving loans was 718. Repeat Finding from Prior Years: No Recommendation: The College should implement a control process to ensure proper notification of loans is sent to students and parents within the timeframe required by DOE. Views of Responsible Officials: The Director of Financial Aid agrees with the finding.
2025-005 Direct Programs – Department of Education ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – NSLDS Reporting Significant Deficiency in Internal Controls Over Compliance Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035). 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 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. The Certification Date must be within 60 days of the Effective Date of the Status reported. Condition: During our review of the student statuses on NSLDS, we noted 3 students with the status of “no record found”, and 18 students where the status change was not submitted within the required timeframe established by DOE. Cause: The College’s existing control procedures to ensure that student status are reported accurately and timely in NSLDS were not functioning. Effect: An incorrect status could impact a student’s future awarding and packaging of Title IV. Questioned Costs: None Sampling: A nonstatistical sample of 60 students out of 1,696 students were selected for testing. Repeat Finding from Prior Years: No Recommendation: The College should implement a control process to ensure student status changes are reported accurately and timely to NSLDS. Views of Responsible Officials: The Director of Financial Aid agrees with the finding.
2025-006 Direct Programs – Department of Education ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement to or on Behalf of Students Material Weakness in Internal Controls Over Compliance Criteria: The Federal Pell Grant program provides grants to eligible students enrolled in eligible undergraduate programs and certain eligible post-baccalaureate teacher certificate programs and is intended to provide a foundation of financial aid. The program is administered by the Department of Education (DOE) and postsecondary educational institutions. Maximum and minimum Pell Grant awards are established by statute, but the amount for which each student is eligible is based on Maximum or Minimum Pell Grant eligibility criteria or the student’s SAI. DOE provides funds to the institution based on actual and estimated Pell expenditures. Condition: During our review of the calculation of student disbursements, we noted 2 students who were not awarded the full amount of Pell for which they qualified. Both students were registered in the summer session but were excluded from the financial aid disbursements for the summer session. Cause: The College’s existing control procedures to ensure that students receive the full amount of Pell for which they qualify were not functioning properly. Effect: The College excluded these students from the financial aid disbursements for the summer session. As a result, 2 students did not receive Pell for the summer session. Questioned Costs: None Sampling: A nonstatistical sample of 60 disbursements out of 6,700 disbursements were selected for testing. Repeat Finding from Prior Years: No Recommendation: The College should implement a control process to ensure all sessions are properly identified and taken into consideration when creating a student’s financial aid package. The College should consider making these students whole and verifying that other summer session students were not precluded from receiving Pell awards. Views of Responsible Officials: The Director of Financial Aid agrees with the finding.