Audit 387869

Finding 2025-001, Repeat of 2024-002 Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Criteria: The College must comply with 34 CFR Section 690.83 and 34 Section 685.301(a)(2). Condition: We tested 40 samples for eligibility, and noted that 12 of the samples had reporting errors related to the disbursement dates to Common Origination and Disbursement (COD). 11 of the errors related to Pell disbursements and one related to a disbursement of a direct loan. Cause: The College did not have a procedure in place to properly review COD disbursement dates to verify all students had the proper reporting in COD. Effect: The provisions of 34 CFR Section 690.83 and 34 Section 685.301(a)(2) were not followed and thus 11 students had incorrect reporting of one day in COD related to Pell disbursements and one student had incorrect reporting of 8 days related to a Direct Loan disbursement. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date matches the student account. View of responsible officials and planned corrective actions: The Director of Financial Aid will review and verify the funds that were disbursed to the students’ account match the disbursement dates in COD on the date the transfer batch report is sent to the College’s Business Office by pulling a reconciliation file from COD. The Director of Financial Aid also has in place to pull students who need Pell or Direct Loans to be disbursed by running a report out of CAMS instead of running a selection set in Powerfaids. Monthly reconciliations for both fund types will be completed every 30 days.

Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Federal Supplemental Educational Opportunity Grants, Assistance Listing 84.007 Direct Loan Student Loans, Assistance Listing 84.268 Criteria: The College must comply with 34 CFR Section 668.22(f). Condition: We tested of nine official withdrawals, which included four students that officially withdrew in the Spring semester, with two of those who withdrew subsequent to spring break. We noted the incorrect amount of total days in the Spring semester was used in the return of funds calculation for all students who withdrew in the Spring semester. Additionally, the two of the students that officially withdrew subsequent to spring break incorrectly had included in the total number of days attended in the semester in their return of funds calculation. Cause: The College does not have procedures in place to properly review days used and attended within the return of funds calculation. Effect: The provisions of 34 CFR Section 668.22 were not followed, and thus a total of four students had incorrect return of funds calculations. Questioned Costs: Known question costs total $2,801 in Title IV aid that should have been returned as a result of our testing of nine official withdrawals. Upon additional analysis, there were no other official withdrawals in the Spring semester who were impacted by these errors. Recommendation: The College should implement a process and controls to verify calculations before finalizing returns. View of responsible officials and planned corrective actions: The Director of Financial Aid has verified in the Student Aid Handbook to include the weekend after the last day of class to the next full day of instruction (includes Saturday and Sunday). Powerfaids has been updated to include these other days. Before finalizing any returns, the Assistant Director of Financial Aid will review the R2T4.

Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Federal Supplemental Educational Opportunity Grants, Assistance Listing 84.007 Direct Loan Student Loans, Assistance Listing 84.268 Criteria: The College must comply with 34 CFR Section 668.22(a). Condition: We tested of nine unofficial withdrawals, which included eight students enrolled in modules. For four of these students, the College used the number of days in the module the student withdrew from, instead of using the total amount days the student was enrolled in on the first day of the period or at any time during the period, based on the Title IV rules for modular enrollment. This resulted in the incorrect denominator and inaccurate calculations of earned and unearned aid. For one sample, the student earned sufficient credit hours in the first Fall module to be considered half-time. However, the College still performed a return of funds calculation when the student withdrew from the second module, even though no return of funds was required based on the Title IV rules for modular enrollment. Upon further analysis, there were 34 students that withdrew from the College during the year that were enrolled in modular programs and 12 of those students had an incorrect return of funds calculation. Cause: The College did not have adequate procedures to ensure that the return of funds calculations for modular students were performed in accordance with federal regulations. In addition, the College's procedures did not include controls to identify circumstances in which return of funds were not required for modular students, such as when a student has already earned sufficient credit hours before withdrawal. Effect: Incorrect return of funds calculations for modular students led to inaccurate determinations of earned and unearned Title IV aid. Questioned Costs: Known question costs of $4,743 in Title IV aid that should have been returned as a result of our testing, and $3,480 in Title IV aid that was returned and should not have been, from the original nine unofficial withdrawals. Upon additional analysis, there was $1,656 in Title IV aid that should have been returned as a result of our testing, and $22,829 of Title IV that was returned and should not have been. Total questioned costs are $32,708. Recommendation: We recommend the College implement controls to ensure the number of days used in the return of funds calculation is accurate based on the module-specific rules. We also recommend the College implement a review process to confirm whether a student has completed sufficient coursework to be considered half-time, thereby exempting them from the return of funds requirements, and to provide training to financial aid staff on the return of funds requirements from students enrolled in module programs. View of responsible officials and planned corrective actions: The Director of Financial Aid will review the student’s enrollment on a module-by module basis at the time of withdrawal to determine the applicable payment period and correct number of days in the period. The Director of Financial Aid will develop a standardized R2T4 checklist for module programs that include identification of all modules within the payment period, confirmation of the student’s start and end dates for each module, and documentation of the total days in the payment period and days completed a the time of withdrawal. To ensure appropriate identification of students who may be exempt from R2T4 requirements due to completion of sufficient coursework, the Director of Financial Aid will establish a formal review process to include the following: 1. Prior to completing an R2T4 calculation, Director of Financial Aid will verify whether the student successfully completed coursework equal to or greater than half-time enrollment, in accordance with federal regulations. 2. This review will include confirmation of: a. Completed credit hours b. Applicable academic records or grades 3. Documentation of the half-time determination will be maintained in the student’s financial aid file to support exemption decisions when applicable. The College will enhance training efforts to ensure staff are fully informed of R2T4 requirements specific to module-based enrollment. Training will be conducted annually and incorporated into onboarding for new staff.