Audit 45554

Finding 2022-001 Entrance Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must provide students with entrance counseling to explain the loan obligation, including the borrower?s rights and responsibilities, prior to a loan disbursement to a first-time Federal Direct Loan borrower. The required elements of entrance counseling are the reinforcement of repayment, the consequences of a default, that payment is required regardless of educational outcome and employability, and to explain the use of the promissory note. The counseling must be conducted in person, by audiovisual presentation, or by interactive electronic means. Context: During our testing, we noted 2 instances in a sample of 61 students in which evidence of entrance counseling could not be provided by the College. Cause: Administrative oversight. The College did not properly monitor the disbursement of funds with the students who had completed the entrance interview. These students may not have been informed of their rights and responsibilities under the Federal Direct Loan Program. Recommendation: The staff at Columbia College should ensure that all students participating in the Federal Direct Loan Program receive the initial loan counseling prior to the disbursement of funds. This should be evidenced with a copy of the entrance interview in the students? files. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid Officers will check Common Origination Disbursement (COD) to ensure that the student has a valid entrance counseling. The counselor will provide a comment that the entrance counseling has been reviewed in the comment section of our Financial Aid system.

Finding 2022-002 Exit Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Context: During our testing, we noted 4 instances in a sample of 61 students in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates. Recommendation: We recommend that the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this counseling should be retained by the College. Views of Responsible Officials and Planned Corrective Actions: The Director of Financial Aid will ensure that all students who withdraw or drop below half-time school-hours will complete exit counseling. Enrollment reports will be reviewed, and the appropriate action will be taken. Students who withdraw will complete the exit counseling at the time of withdrawal. Students who withdraw with notification will be conducted by phone, email, and a certified letter with the steps to complete the exit counseling.

Finding 2022-001 Entrance Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must provide students with entrance counseling to explain the loan obligation, including the borrower?s rights and responsibilities, prior to a loan disbursement to a first-time Federal Direct Loan borrower. The required elements of entrance counseling are the reinforcement of repayment, the consequences of a default, that payment is required regardless of educational outcome and employability, and to explain the use of the promissory note. The counseling must be conducted in person, by audiovisual presentation, or by interactive electronic means. Context: During our testing, we noted 2 instances in a sample of 61 students in which evidence of entrance counseling could not be provided by the College. Cause: Administrative oversight. The College did not properly monitor the disbursement of funds with the students who had completed the entrance interview. These students may not have been informed of their rights and responsibilities under the Federal Direct Loan Program. Recommendation: The staff at Columbia College should ensure that all students participating in the Federal Direct Loan Program receive the initial loan counseling prior to the disbursement of funds. This should be evidenced with a copy of the entrance interview in the students? files. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid Officers will check Common Origination Disbursement (COD) to ensure that the student has a valid entrance counseling. The counselor will provide a comment that the entrance counseling has been reviewed in the comment section of our Financial Aid system.

Finding 2022-002 Exit Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Context: During our testing, we noted 4 instances in a sample of 61 students in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates. Recommendation: We recommend that the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this counseling should be retained by the College. Views of Responsible Officials and Planned Corrective Actions: The Director of Financial Aid will ensure that all students who withdraw or drop below half-time school-hours will complete exit counseling. Enrollment reports will be reviewed, and the appropriate action will be taken. Students who withdraw will complete the exit counseling at the time of withdrawal. Students who withdraw with notification will be conducted by phone, email, and a certified letter with the steps to complete the exit counseling.