Criteria According to 34 CFR 685.304(b): Counseling Borrowers - Exit Counseling (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a studyabroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition The Federal Government requires that when the student ceases at least half-time study, withdraws from all classes or graduates, the college must provide exit counseling to students within 30 days. During our testing, we noted 6 students, out of a sample of 40, did not have evidence that exit counseling was performed. Cause The College did not have adequate controls in place to ensure that exit counseling was conducted with Direct Loans borrowers following changes in enrollment which require administration of exit counseling for Direct Loans. Effect The College did not meet federal requirements and students did not complete exit counseling following graduation, cease of enrollment. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 6 students, or 15% of our sample, had students that graduated or disenrolled and did not complete exit counseling. Identification as a Repeat Finding, if applicable See finding 2024-001 included in the summary schedule of prior year findings. Recommendation The College should strengthen their procedures to ensure exit counseling is completed for a student when student ceases enrollment at least half-time, withdraws, or graduates from the College. View of Responsible Officials The College agrees with the finding.
Criteria According to 2024-2025 Federal Student Aid Handbook, Volume 4, Chapter 2, Reporting Disbursements Within 15 Days Schools must submit Direct Loan, Pell, and TEACH Grant disbursement records to the COD System no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. See Federal Register Volume 88, Number 120, June 23, 2023. The Department considers that Title IV funds are disbursed on the date that schools (a) credit those funds in their general ledger or any subledger to a student’s account or (b) pay those funds to a student or parent directly. Title IV aid is disbursed even if schools use their own funds in advance of receiving program funds from the Department. 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. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 32 students, out of a sample of 40, were not reported within the required timeframe by 12-19 days. Cause The College maintains established policies and procedures to ensure that disbursement records are reported to the Department of Education through the COD system within the required fifteen-calendar-day timeframe. In this instance, however, staffing transitions within the financial aid department resulted in a delay of two to three weeks in submitting the records. Effect The College did not report Direct Loan disbursements to COD within the required time frame. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 32 students, or 80% of our sample, were not reported to COD within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that management provide adequate cross-training for staff processing Direct Loan disbursements to ensure all Direct Loans are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.
Criteria According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2024: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED or accessed on the Enrollment Maintenance Page via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 30 out of 40 students were reported late to the NSLDS by 82-259 days. Cause The College did not have appropriate review to ensure that enrollment-status changes were reported to NSLDS in a timely manner. Staffing transitions within the Registrar’s Office during the spring semester contributed to the delay in reporting. Effect The College did not report the student’s correct status within the required timeframe, which may affect the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 30 students, or 75% of our sample was not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that management enhance cross-training among employees involved in the NSLDS reporting process to support consistency and continuity in meeting federal reporting requirements. View of Responsible Officials The College agrees with the finding.
Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 7, that had an unclaimed fund exceeding the federal day limit by 78 days. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs $132 pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 7 students selected for testing, 1 student, or 14% of our sample had an unclaimed fund exceeding the federal day limit. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that the College consider reviewing and, if necessary, refining its policies and procedures related to unclaimed funds, including the identification of aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.
Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; 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 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 5, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 266 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 1 student, or 20% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that the College consider refining its process for completing and reviewing Return of Title IV calculations to help ensure funds are returned to the Department of Education within the required timeframe. View of Responsible Officials The College agrees with the finding.