Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster, and Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 668.24 An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. The Secretary considers the institution's policy to be reasonable if— (1) The policy is at least as strict as the policy the institution applies to a student who is not receiving assistance under the title IV, HEA programs; (2) The policy provides for consistent application of standards to all students within categories of students, e.g., full-time, part-time, undergraduate, and graduate students, and educational programs established by the institution; Condition Federal regulations require the College to consistently apply the standards to all students. During our testing, we noted 3 students, out of a sample of 60, who were not properly notified they were not in compliance with the College’s satisfactory academic progress policy. Cause The College did not consistently apply their satisfactory academic progress policy. Effect Students were not properly notified they were placed on academic probation. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 3 student, or 5% of our sample, had Pell awards in excess of their eligible amount. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure their satisfactory academic performance policy is consistently followed. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.
Finding number: 2024-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster, and Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 690.62(b)(1)(ii): If an institution determines that the amount of a Federal Pell Grant for that student exceeds the cost of attendance for that year, the amount of the Federal Pell Grant must be reduced until the Federal Pell Grant does not exceed the cost of attendance at such institution and does not result in a title IV credit balance under 34 CFR 668.164(h). Condition Federal regulations require the College to ensure need based aid (Pell) does not exceed the calculated financial need of the student. During our testing, we noted 1 student, out of a sample of 60, who received Pell awards in excess of their calculated need. Cause The College did not properly reduce the need of the student by their expected family contribution, resulting in Pell being awarded in excess of financial need. Effect The college over awarded Pell in the amount of $1,061. Questioned Costs 1,061 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 1 student, or 1.7% of our sample, had Pell awards in excess of their eligible amount. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell funds disbursed do not exceed the student’s documented need. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.
Finding number: 2024-005 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The College’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic probation. If the student does not improve, as described in the SAP, the student will be placed on academic suspension from the College unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that three students failed to meet the minimum standards established by the SAP but the College was unable to provide support showing the students were notified they were being placed on academic probation. Cause The College failed to have proper review procedures in place to identify and notify students who did not meet the minimum SAP standards. Effect Students were not properly notified they did not meet the minimum SAP standards and potentially ineligible to receive any future federal aid. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 3 students, or 5%, were not properly placed on academic probation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.
Finding number: 2024-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033 Award year: 2024 Criteria According to 34 CFR 675.10: (a) An institution shall make employment under FWS reasonably available, to the extent of available funds, to all eligible students. (b) An institution shall establish selection procedures and those procedures must be— (1) Uniformly applied; (2) In writing; and (3) Maintained in the institution's files. Condition The College’s policy regarding Federal Work Study (“FWS”) requires the student to sign a work study agreement prior to working. One of the twenty-five selected students who received FWS did not have a signed agreement and 1 of 25 selected students received FWS above the amount included in their award letter without approval from the financial aid department. Cause The College failed to have proper review procedures in place to ensure agreements were in place for work study participants and that students earned FWS did not exceed the amounts reported per their award letters.. Effect The college was not in compliance with their FWS policy. Questioned Costs $798 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 2 students, or 8%, were not in compliance with the College’s FWS policy. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should continue to strengthen its controls surrounding FWS policy to ensure all students who receive assistance under the title IV program have a signed agreement in place and do not receive FWS amounts in excess of their award letter.. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.
Finding number: 2024-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 690.62(a) The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. Condition Federal regulations require the College to calculate and award pell grant funds based upon the published payment and disbursement schedules. During our testing, we noted 2 students, out of a sample of 60, who received pell awards below their eligible limit of $ 1,848 and $925, respectively. Cause The College did not properly calculate the earned Pell for 2 of 60 tested students. Effect The college under awarded Pell in the amount of $2,773. Questioned Costs $2,773 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 2 students, or 3.33% of our sample, were under awarded Pell grants totaling $2,773. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell awards are properly calculated. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report and has awarded the correct amounts to the student’s accounts.
Finding number: 2024-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 88, Number 120): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) disbursements made to students accurately based on date award was credited to student directly. During our testing, we noted 1 student, out of a sample of 60, did not have the correct disbursement date reported to the Common Origination System based on disbursement date per College records. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD are recorded accurately, however, in this case the procedures were not completed properly causing variance between actual disbursement date and disbursement date per COD. Effect The College did not report the correct Pell disbursement date to COD accurately based on College records. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 1 students, or 1.7% of our sample, had disbursement information not properly recorded. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell funds disbursed are reported accurately based on when awards were credited to student account. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.
Finding number: 2024-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 668.57: If an applicant is selected to verify any of the following information, an institution must obtain the specified documentation. (a) Adjusted Gross Income (AGI), income earned from work, or U.S. income tax paid. (i) A copy of the income tax return or an Internal Revenue Service (IRS) form that lists tax account information of the applicant, his or her spouse, or his or her parents, as applicable for the specified year. The copy of the return must include the signature (which need not be an original) of the filer of the return or of one of the filers of a joint return; Condition If an applicant is selected to verify any of the following information, an institution must obtain the specified documentation. During our testing, we noted 3 students, out of a sample of 25, where the College was unable to provide documentation showing they obtained and verified the required information. Cause The College did not properly follow it’s policies and procedures regarding documentation retention and was unable to provide supporting documentation showing the required information was verified for the students in question. Effect The College did not adequately follow proper document retention procedures surrounding the verification process for Federal aid recipients selected for verification. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 3 students, or 12% of our sample, had disbursement information not properly recorded. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all required documentation is properly retained. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.
Finding number: 2024-010 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 8 students, out of a sample of 25, where the college was unable to provide support showing the aid was returned. Cause The College did not ensure that the regulations were met in regard to refunding Title IV funds when maintaining support for returned aid. Effect The College was unable to provide support showing the correct amount of Title IV funds were returned to the Department of Education. Questioned Costs $7,396 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 8 students, or 32% of our sample, did not have proper supporting documentation showing the proper return of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review their current policies and procedures to ensure proper support is maintained. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report
Finding number: 2024-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 students, out of a sample of 25, where the amount of aid to return was improperly calculated and returned. Cause The College did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $1,254 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 1 students, or 4% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report
Finding number: 2024-012 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018: 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 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. We noted 1 student, out of a sample of 60, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. Effect The College did not report the students’ status changes to NSLDS, which may impact the students’ loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 1 students, or 1.7% of our sample was not reported within required timeframe of 60 days. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should review their current policies and procedures to ensure student status changes are reported within the established timeframe. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report