Audit 390070

Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. In accordance with 34 CFR 668.22(b) and (d)(4),the institution must return those funds for which it is responsible under paragraph (a) of this section to the respective title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. An institution does not satisfy this requirement if— (i) The institution's records show that the check was issued more than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 45 days after the date that the institution becomes aware that the student will not or has not begun attendance. Condition: It was noted during our testing of R2T4 calculations that 13 of 60 students selected for R2T4 testing had an instance of non-compliance due to Title IV funds not being returned within the 45 day time limit. Questioned Costs: None. Context: During our audit procedures, we noted 13 of the 60 students selected for R2T4 testing had Title IV funds not returned within the 45-day time limit. Cause: During fiscal year 2025, the District implemented additional procedures to strengthen the R2T4 process in response to the fiscal year 2024 audit finding. Because the 2024 audit report was issued after certain R2T4 calculations had already been completed, the newly implemented procedures resulted in corrections to some previously finalized calculations. 4 of the 13 instances of non‑compliance were attributable to these post‑implementation corrections. The remaining 9 instances of non‑compliance resulted from human error. Effect: The District did not return Title IV funds within the required time period. Repeat Finding: Yes, 2024-001. Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Views of Responsible Officials: Management concurs with the finding.

Criteria: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of late reporting of student status changes. Questioned Costs: None. Context: During our audit procedures, we noted two instances of noncompliance. Cause: The District's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, 2024-002. Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Management concurs with the finding.