Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Eligibility Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Material Noncompliance Criteria or Specific Requirements 34 CFR section 685.203: In the case of an undergraduate student who has not successfully completed the first year of a program of undergraduate education, the total amount the student may borrow under the Direct Subsidized Loan Program may not exceed $3,500 for a program of study of at least a full academic year in length. 34 CFR section 690.62: The Pell grant for an academic year is based upon the payment and disbursement schedules released by the U.S. Department of Education for each award year. The payment schedules take into account the student?s cost of attendance, EFC and enrollment status. Condition Material Weakness? During testing over the eligibility requirements, the following deficiencies were noted: ? 1 of 68 students loan disbursements exceeded the subsidized loan annual limit for first year students. ? 2 of 68 students total financial aid packages exceeded their cost of attendance resulting in an overpayment of Title IV assistance. ? 14 of 68 students were not disbursed the correct amount of Pell grant based on their enrollment status. ? The College failed to report loan disbursement to NSLDS for 1 out of 68 students. Questioned Costs $19,792 of loan disbursements that exceeded the subsidized loan annual limit for first year students. $10,442 of overpayments as a result of inaccurate financial aid package calculations. $3,804 of overpayments and $8,583 of underpayments as a result of inaccurate disbursement calculations. Context The College contracts with a third-party servicer to perform one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school. The overpayment of Pell grants was due to the College not updating the enrollment status of the students. Additionally, the College did not review the service provider?s calculations or reporting of information to ensure compliance with eligibility requirements. A nonstatistical sample of 68 students out of 346 students were selected for eligibility testing. The College disbursed $3,984,674 of Title IV funds to the students attending the College during the 2021-2022 award year. Effect The College is not in compliance with the Federal eligibility requirements described in the OMB Compliance Supplement. Cause The College did not retain supporting evidence or ensure eligibility requirements were met for students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student eligibility requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.
Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 1 of 22 Return to Title IV calculations were incorrectly calculated. ? 1 of 22 Return to Title IV calculations were performed outside of the allowable timeframe. ? 5 of 22 student overpayments calculated were not returned to Title IV programs. ? 3 of 22 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Questioned Costs Questioned costs include $6,448 of funds that were not returned to U.S. (ED). Context The College did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. A nonstatistical sample of 22 R2T4 calculations out of 106 R2T4 calculations were selected for Return to Title IV testing. Effect Without proper monitoring of accuracy and student withdrawals, the College risks noncompliance with the above referenced criteria. Cause The College did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding No Recommendation The College should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.032 Federal Agency: U.S. Department of Education Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirement 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campusbased programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition Significant Deficiency? The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Questioned Costs There are no questioned costs associated with this finding. Context The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Effect The College is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The College does not have a process in place to retain reporting documentation. Repeat Finding: No Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Type of Finding: Material Weakness in Internal Control and Noncompliance Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Material Weakness ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 3 of 60 students program begin dates were not accurately reported on NSLDS (enrollment date per student accounts do not agree to begin date per NSLDS). ? 9 of 60 students certification dates exceeded the 60-day timing requirement. ? 53 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 53 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? The College failed to provide NSLDS documentation for 23 of 60 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College disbursed financial aid to approximately 346 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 346 students were selected for enrollment reporting testing. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.032 Federal Agency: U.S. Department of Education (ED) Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements 34 CFR 668.164(i): The earliest an institution may disburse SFA funds (other than FWS) (either by paying the student directly or crediting the student?s account) is 10 days before the first day of classes of the payment period or module for which the disbursement is intended. 34 CFR 668.165 (a)(6)(i)): The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan. Condition Significant Deficiency - During testing over the disbursement requirements, the following deficiencies were noted: ? 3 of 68 students were disbursed aid greater than 10 days before the first day of classes for the payment period. ? The College failed to provide evidence of loan disbursement notifications for 30 of 40 students. Questioned Costs There are no questioned costs associated with the noncompliance. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. Due to turnover of key department employees and termination of the service agreement during the fiscal year, the College did not retain evidence of loan disbursement notifications sent to students who received direct loan assistance. Additionally, the College did not ensure compliance with disbursing Pell assistance within the acceptable payment period for the term it was intended. A nonstatistical sample of 68 students out of 346 students were selected for disbursement testing. Effect The College is not in compliance with the Federal disbursement requirements described in the OMB Compliance Supplement. Cause The College did not comply with Federal disbursement requirements students under the Pell Grant and Direct Loan Programs. Repeat Finding No Recommendation The College should implement a process to review, update, and verify student disbursement requirements. The College should maintain a document retention policy in order to comply with Title IV laws and regulations.