Finding No.: 2023-004 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Reporting Questioned Costs: $--- Criteria: Institutions are required to submit origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. Origination records include the student information such as Social Security number, award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and Condition: For all 40 origination records tested, the College reported the cost of attendance from the SY2021- 2022 handbook. The current cost of attendance, as per the SY2022-2023 handbook, exceeds the amounts reported in the origination records. Additionally, the College did not consider the applicant's enrollment status (full-time, three-fourths-time, half-time, or less than half-time) when determining the cost of attendance; instead, it applied full-time status uniformly to all applicants. Cause: The discrepancies identified in the origination records stem from lack of systematic review and update processes for financial aid records. Effect: The reliance on outdated cost of attendance data and the uniform application of full-time status may lead to incorrect calculation of financial awards to students. Recommendation: The College should establish a systematic process for reviewing and updating the origination records prior to submission to COD System. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.
Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Verification Questioned Costs: $53,441 Criteria: 34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4 requires an institution to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. Institutions shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. Institutions shall also require applicants to verify any information institution has reason to believe is inaccurate and Condition: For 6 (or 19%) of 31 students tested, incorrect verification procedures were performed by the College. Standard verification (V1) was performed instead of the required custom verification (V4). , whereas V4 requires verification their statement of education purpose. For 1 (or 3%) of 31 students tested, verification worksheet is missing and required verification procedure is not performed. For 5 (or 16%) of 31 students tested, discrepancies were found in the verification worksheet versus . For 3 (or 10%) of 31 students tested, corrections required for ISIRs were not made. Cause: The College did not effectively monitor compliance with applicable verification requirements. Effect: The College is in noncompliance with applicable verification requirements. Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.
Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Gramm-Leach-Bliley Act Student Information Security Questioned Costs: $--- Criteria: The Gramm-Leach-Bliley Act (GLBA) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistrance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions should comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition: The College does not have a qualified individual to oversee the GLBA information security program. Additionally, the Company does not have an existing GLBA information security program in place. Cause: The non-compliance is due to a lack of awareness and understanding of the GLBA requirements and the absence of a formalized process for establishing and maintaining an information security program Effect: The College is in noncompliance with applicable GLBA requirements. Recommendation: The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.
Finding No.: 2023-007 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Disbursements to or on Behalf of Students Questioned Costs: $--- Criteria: 34 CFR 668.165(a)(1)) requires institutions to 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) prior to making a disbursement. When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition: The College does not provide notification to students regarding the amount and type of Title IV funds they are expected to receive, as well as how and when those disbursements will be made. No questioned cost is identified as the non-compliance was related a notification requirement. within the required 14-day timeframe. No questioned cost is identified as the credit balance was subsequently disbursed to the students. Cause: The non-compliance is due to inadequate processes and controls for communicating financial aid information to students. This includes a lack of established procedures for generating and distributing notifications to students. Effect: The College is in noncompliance with applicable student notification and time frame requirements for paying credit balances to students. Recommendation: The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of award letters or college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day timeframe to maintain compliance with federal regulations. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.
Finding No.: 2023-008 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Enrollment Reporting Questioned Costs: $--- Criteria: Institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). 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 Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two , both of which need to be reported accurately and have separate record types. Condition: For 24 (or 60%) of 40 students tested, campus level information is not updated in NSLDS. Campus-level record data elements include OPEID number, enrollment effective date, enrollment status and certification date. For 21 (or 53%) 40 students tested, program level information is not updated in NSLDS. Program- level record data elements include OPEID number, Classification of Instructional Programs (CIP) code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status, program enrollment effective date. Cause: The non-compliance is due to inadequate processes and controls for monitoring and updating students' enrollment status in the NSLDS. This includes delays in processing updates and a lack of oversight to ensure accurate reporting. Effect: The College is in noncompliance with applicable enrollment reporting requirements. Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.