Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.
Finding 2022-002 ? Refund of Credit Balances (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: Per 34 CFR 668.164(h)(2), Culver Stockton College is required to pay or make available any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs to ensure compliance with special tests and provisions. Condition: During the course of our audit, we sampled 60 students that received Title IV funds. Within that sample, one student had a credit balance and the College failed to refund the credit balance within the 14-day period and did not have the student or parent?s authorization to retain a credit balance. Cause of Condition: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: None. Perspective Information: Because this is a repeat finding, this appears to be a systemic problem. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.
Finding 2022-003 ? Early Disbursement of Title IV Funds (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(i)(2), Culver Stockton College may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5) unless the College is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A). This exemption only applies to schools with a cohort default rate of less than 15 percent for each of the three most recent fiscal years for which data is available. Condition: In our sample of 60 students, the College disbursed Title IV funds to fourteen first-year, first-time borrowing students before the 30-day period expired. However, the College did not meet the exemption to the delayed disbursement requirement because its cohort default rate was more than 15 percent for one of the three most recent fiscal years available. Cause of Condition: The College typically falls under the exemption and is allowed early disbursement. They were aware of the year in which the cohort default rate was above 15 percent and properly followed the rules to delay disbursement until 30- days. However, they were not aware that the exemption takes into consideration each of the three most recent fiscal years available. Effect: Any deviations from Student Financial Assistance requirements may potentially jeopardize the College?s program eligibility. Questioned Costs: None. Perspective Information: Because the College was not aware that they did not meet the exemption, this is considered a systemic problem. Recommendation: We recommend the College provide additional training for staff involved in the disbursement of Title IV funds and ensure that the Official Cohort Default Rate notification is carefully reviewed and provided to all relevant personnel to ensure compliance with all changes mentioned in the notification. Also, implementing additional monitoring procedures to ensure disbursements are performed within the correct time periods allowed would help strengthen adherence to the requirements.
Finding 2022-004 ? Calculation of Return of Title IV Funds (R2T4) and NSLDS Reporting (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: According to 34 CFR 668.22(b), the withdrawal date for a student who withdraws from an institution that is required to take attendance is the last date of academic attendance. As stated on Page 55 of Culver Stockton College?s 2021- 2022 Academic Catalog, faculty are required to record attendance in all college courses in the College?s e-learning system. Additionally, the effective date for the withdrawn status to be reported to NSLDS is the withdrawal date used by the institution in accordance with 34 CFR 668.22(b). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. Two of the 8 students selected did not have the correct date of withdrawal used in calculating the percentage of Title IV aid earned. Moreover, the wrong effective date of withdrawn status was reported to NSLDS for these two students. Cause of Condition: The College used the date of withdrawal, which was typically the date the student completed a withdrawal form rather than the date of last attendance as the withdrawal date for the R2T4 calculation and NSLDS reporting. Effect: Since the wrong date of withdrawal was used in the R2T4 calculation, the percentage of Title IV aid earned was incorrect. This would cause the College to return more, or less, funds than necessary. The return of Title IV funds can impact the student?s outstanding Direct Loan balance and Pell eligibility limits since returning an incorrect amount also results in an incorrect balance. Lastly, reporting the incorrect date to NSLDS would cause the grace period to begin on an incorrect date. Questioned Costs: There are no questioned costs. One of the students had earned 100% of their Title IV aid and the incorrect date did not change the percent earned. The other student was awarded Pell but decided to decline their award when they withdrew so they could receive the full Pell amount at the college in which they were transferring to. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of using the incorrect date is limited. Recommendation: We recommend the College employ stronger oversight in this area by implementing procedures to ensure the status of students is updated correctly and timely. A secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect. Communication with other offices is also important to ensure all steps of student withdrawals are being completed correctly and timely.
Finding 2022-005 ? Calculation of Return of Title IV Funds (R2T4) (Not a Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.?s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: 34 CFR 668.22(h) specifically details the responsibility of the student to return unearned aid once the institution has allocated the unearned funds for which the College is responsible for in accordance with 34 CFR 668.22(g). Condition: During the course of our audit, we selected a sample of 8 students who withdrew or did not maintain attendance during a payment period to test for proper R2T4 calculations. One student?s R2T4 calculation was not completed correctly resulting in the College returning more funds than required. Cause of Condition: The College did not complete the entire R2T4 calculation and stopped at Step 6 after determining the amount the school must return. Effect: The College returned both the institutional and student portions of the unearned funds. However, the student should have been responsible for their own portion. Therefore, the College incurred additional cash disbursement than necessary. The student?s portion was $100. Questioned Costs: None. Perspective Information: The College only had withdrawals totaling 26 students for the fiscal year with many of those not receiving Title IV funding. Therefore, the impact of the incorrect calculation is limited. Recommendation: We recommend the College ensure it is completing all steps of the R2T4 calculation to confirm the calculation is complete and accurate. As stated above in Finding 2022-004, a secondary review of the calculation should identify errors in calculations and reduce the risk of the return being incorrect.