Audit 415646

US Department of Education Program Name: Student Financial Assistance Programs Cluster Assistance Listing #: 84.007; 84.033; 84.063; 84.063A; 84.268 Finding: 2026 – 001 Special Tests and Provisions – Transfer Student Monitoring Condition: We tested a sample of five transfer students for compliance with NSLDS Transfer Student Monitoring requirements and noted one exception. The College disbursed $2,408 in Federal Pell Grant funds to a transfer student across three installments during the year without first enrolling the student in NSLDS Transfer Student Monitoring. The College's standard NSLDS financial aid history review was performed prior to disbursement and identified no eligibility issue. The remaining four students tested had been properly enrolled in Transfer Monitoring prior to disbursement. Cause: The College's packaging instructions direct staff to enroll transfer students in Transfer Monitoring, but the step is not documented in the student file or subject to supervisory review. As a result, the omission for this student was not detected before disbursement. Effect: Because the College's NSLDS financial aid history review did occur and confirmed eligibility (Pell lifetime eligibility used: 50%; no Direct Loan or other loan activity), no over-award or ineligibility resulted, and no questioned costs arose. However, the lack of documentation or independent verification of the Transfer Monitoring step creates an increased risk that a future disbursement could be made to an ineligible transfer student without detection. Criteria: 34 CFR 668.19 requires an institution to obtain a transfer student's NSLDS financial aid history before disbursing Title IV funds, including enrollment in Transfer Student Monitoring, and prohibits disbursement until that information is obtained (or seven days have passed without an ineligibility response). 2 CFR 200.303 requires effective internal control over Federal awards providing reasonable assurance of compliance with Federal requirements. Recommendation: We recommend the College formalize Transfer Student Monitoring as a stand-alone, documented procedure — separate from the NSLDS eligibility review — with supervisory sign-off required before disbursement. Views of responsible personnel and planned corrective actions: The College agrees with this finding and will revise its disbursement procedures to require Transfer Monitoring enrollment and alert review prior to disbursement of Title IV funds. See corrective action plan on page 48.