Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and five repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. We also noted that published policies did not always align with what is being done in practice. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: 2023-004. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. We also recommend the College review policies and procedures to ensure they align with what is being done in practice. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $21,943 Context: Out of 22 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $11,093 of Pell and $10,250 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: 2023-005. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. We also recommend that the College review their policy and procedures and ensure that practices align with what the stated policy is. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Pell Grants Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: The 24 students tested for proper NSLDS enrollment status did not have their enrollment updated for the year under audit. All of these students were corrected during the audit and a full file review was performed to update the remaining students at the College. Cause: Due to turnover in the financial aid office, NSLDS was not updated accurately for the 23-24 year. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: 2023-007. Recommendation: We recommend that the College put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2023-2024 Financial Aid Year Condition: Students were not initially appropriately awarded direct federal loans. Criteria: 34 CFR 685.200(a) Questioned Costs: $16,909 Context: Out of 22 students tested, 7 students were not awarded aid appropriately based on need analysis. Four students were awarded federal direct loans in excess of cost of attendance, resulting in a total of $7,084 over awarded to them. Three additional students and one student who was exceeding cost of attendance received subsidized loans in excess of financial need, resulting in a total of $9,825 over awarded to them. Cause: The College did not review flags in the information system before disbursing federal financial aid. Effect: Students received federal loans for which they were not eligible. Identification as repeat finding, if applicable: 2022-007, 2023-008 Recommendation: We recommend the College ensure that all flags in the student information system are cleared before disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Pell Grants Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly. Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83 Questioned Costs: $0 Context: Out of 22 students tested, 20 students did not have the correct disbursement dates for both Fall and Spring terms. Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: 2022-006, 2023-010 Recommendation: We recommend the College implement procedures to reconcile monthly FDL and Pell disbursements to student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Pell Grants Federal Award Identification #: 2023-2024 Financial Aid Year Condition: Unearned Title IV aid was not returned accurately and timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $6,629 Context: Out of 5 students tested, 3 did not have correct returns of Title IV funds. 2 online students did not have an R2T4 performed after their withdrawal or Pell recalculated to ensure they were paid only for classes they began attendance in. This resulted in $3,511 in Federal Direct Loans and $3,118 in Pell under returned to the department of education. Another online student had an R2T4 performed, however the break day setup in the R2T4 calendar was done incorrectly and did not include weekends for breaks longer than 5 days. This resulted in an over return of Pell of $47. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. The R2T4 calendar was not correctly set up. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: 2023-011. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2023-012. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.