Finding 2022-001 Packaging and Disbursing Pell Grant Noncompliance Criteria: A school must determine and calculate a student?s eligibility for a Federal Pell Grant during a payment period. To calculate the Federal Pell Grant award the school must use the payment and disbursement schedules published by the Secretary for each award year as per 34 CFR 690.62. Statement of Condition: The Federal Pell Grant amount disbursed does not match the Pell Chart based on the student?s Expected Family Contribution from the valid ISIR. Cause: The institution inadvertently used the wrong Pell Amount. Effect: In one (1) of forty-nine (49) original student files selected with a Federal Pell Grant disbursement, the Institution made a disbursement of Federal Pell Grant funds that was not calculated based upon the valid ISIR/Expected Family Contribution nor under the Federal Pell Grant Payment Schedule. Description of nature and extent of the issues reported: The sample student?s Federal Pell Grant fund was calculated, awarded, and disbursed inaccurately. Questioned cost: See Chart Recommendation: The Institution should set up procedures to prevent future incidences and ensure compliance with 34 CFR 690.62. Views of Responsible Officials: Los Angeles Chapter National Tooling & Machining Association Training Center Trust dba NTMA Training Centers acknowledges this finding and will apply the recommendation.
Finding 2022-003 Disbursing Funds for the Title IV Programs - Noncompliance Criteria: In accordance with 34 C.F.R. ?668.162 Requesting Funds, under the advanced payment method, an institution must disburse the funds requested as soon as administratively feasible but not later than three business days following the date the institution receives those funds. Statement of Condition: The disbursement of a Federal Pell Grant was made later than three business days after the institution received funds based on the G5 drawn down date. Cause: Unknown. Effect: In two (2) of 215 disbursements to students, the institution did not disburse a Federal Pell Grant within three business days following the date the institution received the funds. Description of nature and extent of the issues reported: The institution did not disburse Federal Pell Grant disbursements to the students within three business days after the institution received funds.
Finding 2022-005 Plus Notice Deficiencies - Noncompliance Criteria: Per 34 CFR 668.165, the Institution must notify the borrower in writing (paper or electronically) of the anticipated date and amount of the disbursement, student?s or parent?s right to cancel all or part of the loan or disbursement, and the procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the direct loan, loan disbursement. Statement of Condition: In four (4) of four (4) files tested with Parent Plus Loans, the Institution did not meet the requirements of notifications, per 34 CFR 668.165(a)(2)-(3) was deficient. In each case, the Instiutition sent one letter to the parent which included the total amount of the Plus loan approval for the entire period, vs. the disbursement amounts (by pay period with the anticipated date for each). The Institution has indicated that for each, a copy of the student?s notification was attached to the parent letters. Accepting this explanation of an attachment, the deficiencies are as follows: ? The parent borrower did not receive notification of the amount of and date for each disbursement. The letter that was provided to the parent was two pages. The first page included the total approved Plus amount (all payment periods), not the disbursement amount for the particular payment period and accordingly, the particular disbursement. The issue here is not gross vs. net considering fees but rather that the letter provided to each parent borrower was not based on individual disbursements but rather the Plus loan approval amount in aggregate. The second page was the notification addressed to the student for the first disbursement (this was not repeated with the second disbursement). The notification included an aggregate amount of all direct loans and did not specify the amount of the Plus loan. ? The parent did not receive a notification for each disbursement as the notification that was attached in each case, to the parent borrower letter, was at the time of the first disbursement. Three (3) of the four (4) students had two disbursements; no additional letter was sent to the parent at the time of the second notification. If a school does not obtain affirmative confirmation, a notification must be sent no earlier than 30 days before and no later than 7 days after crediting the student?s account. Notwithstanding the other deficiencies, the date of the letter does not meet the requirements of the date of the notification for each of the second disbursements. ? The parent did not receive a notification that informed the parent of the parent?s right to cancel. The notification that was attached to the aforementioned letter to the parent regarding the total approved Plus amount was addressed to the student and said ?you have the right to cancel??. There is no mention in the parent letter of attached notification that provides information about the parent?s right to cancel. Cause: Based on the views of the responsible officials to this finding, the cause appears to be a lack of understanding of the requirements. Management?s position is that the notification can be sent to either the parent OR the student and so they believe they have complied with the requirement. Effect: Notifications to parents were not sent which met both the language and timing regulations of Plus notifications. The parent may or may not have been aware of the disbursement amounts, disbursement dates, or the parent?s right to cancel. Description of nature and extent of the issues reported: Four students had plus loans provided by a parent borrower. A total of seven disbursements were made to the four students. Notification regulations in 34 CFR 668.165 (a) were not met in seven (7) of the seven (7) instances.
Finding 2022-002 Disbursement Reporting Requirements for the Title IV Programs - Material Weakness Criteria: In accordance with the requirements at 34 C.F.R. ?685.301(a)(2), a school must submit Direct Loan disbursement records, including the disbursement amount and disbursement date, as defined in 34 C.F.R.1649a), to COD. The most recent Federal Register notice specifies that a school must submit disbursement records no earlier than 7 days prior to the disbursement date and no later than 15 days after making the disbursement. The actual disbursement date is the date that the Direct Loan funds are made available to the borrower (i.e.: posting or crediting the funds to the student?s account). Because several terms and conditions of Direct Loans are tied to the actual disbursement date, this date must be accurately reported. Statement of Condition: The actual disbursement dates of Federal Pell Grant and Direct Loan funds were not reported to COD correctly. Cause: The institution did not update disbursement dates in EDExpress and therefore shows a discrepancy between the date of disbursement on the student?s ledger and the COD disbursement date. Per the institution, not changing the disbursement date in EDExpress was a training discrepancy that has been corrected. Effect: In eighty-two (82) of two hundred fifteen (215) disbursements to students including Federal Pell Grant and Direct Loan funds, the disbursement dates were not updated in COD. Description of nature and extent of the issues reported: The disbursement dates were incorrectly reported to COD for Federal Pell Grant and Direct Loan disbursements.
Finding 2022-004 Determine in a Timely Manner the Date of Withdrawal - Material Weakness Criteria: The date of the institution?s determination (DOD) that the student withdrew should be no later than 14 days after the student?s last date of attendance (LDA) as determined by the institution from its attendance records as per 34 CFR 668.22(b)(1). Statement of Condition: The Institution?s determination of the students? date of withdrawal was later than 14 days. Cause: The institution?s policy is that a student is terminated after 10 consecutive class day absences. The institution?s procedures include reviewing all attendance the subsequent business day. For example, a student who begins 10 consecutive absences on a Monday may complete 10 consecutive absences on a Friday. The institution?s procedure is to review Friday?s absences on a Monday. Effect: In five (5) of eighteen (18) drop students, the Institution?s determination of the date of withdrawals was later than 14 days. Description of nature and extent of the issues reported: The students? DODs were later than the required 14 days after the LDAs. Questioned cost: B9, B10, and B14 have DODs which are 17 days later than the LDAs. B15 has a DOD which is 20 days later than the LDA. B16 has a DOD which is 16 days later than the LDA. Recommendation: The Institution should set up procedures to prevent future incidences and ensure compliance with 34 CFR 668.22(b)(1). The institution may want to consider changing either their absentee policy or their review of student attendance records once a student is close to violating their absentee policy. Views of Responsible Officials: Los Angeles Chapter National Tooling & Machining Association Training Center Trust dba NTMA Training Centers acknowledges this finding and will apply the recommendation.
Finding 2022-002 Disbursement Reporting Requirements for the Title IV Programs - Material Weakness Criteria: In accordance with the requirements at 34 C.F.R. ?685.301(a)(2), a school must submit Direct Loan disbursement records, including the disbursement amount and disbursement date, as defined in 34 C.F.R.1649a), to COD. The most recent Federal Register notice specifies that a school must submit disbursement records no earlier than 7 days prior to the disbursement date and no later than 15 days after making the disbursement. The actual disbursement date is the date that the Direct Loan funds are made available to the borrower (i.e.: posting or crediting the funds to the student?s account). Because several terms and conditions of Direct Loans are tied to the actual disbursement date, this date must be accurately reported. Statement of Condition: The actual disbursement dates of Federal Pell Grant and Direct Loan funds were not reported to COD correctly. Cause: The institution did not update disbursement dates in EDExpress and therefore shows a discrepancy between the date of disbursement on the student?s ledger and the COD disbursement date. Per the institution, not changing the disbursement date in EDExpress was a training discrepancy that has been corrected. Effect: In eighty-two (82) of two hundred fifteen (215) disbursements to students including Federal Pell Grant and Direct Loan funds, the disbursement dates were not updated in COD. Description of nature and extent of the issues reported: The disbursement dates were incorrectly reported to COD for Federal Pell Grant and Direct Loan disbursements.
Finding 2022-004 Determine in a Timely Manner the Date of Withdrawal - Material Weakness Criteria: The date of the institution?s determination (DOD) that the student withdrew should be no later than 14 days after the student?s last date of attendance (LDA) as determined by the institution from its attendance records as per 34 CFR 668.22(b)(1). Statement of Condition: The Institution?s determination of the students? date of withdrawal was later than 14 days. Cause: The institution?s policy is that a student is terminated after 10 consecutive class day absences. The institution?s procedures include reviewing all attendance the subsequent business day. For example, a student who begins 10 consecutive absences on a Monday may complete 10 consecutive absences on a Friday. The institution?s procedure is to review Friday?s absences on a Monday. Effect: In five (5) of eighteen (18) drop students, the Institution?s determination of the date of withdrawals was later than 14 days. Description of nature and extent of the issues reported: The students? DODs were later than the required 14 days after the LDAs. Questioned cost: B9, B10, and B14 have DODs which are 17 days later than the LDAs. B15 has a DOD which is 20 days later than the LDA. B16 has a DOD which is 16 days later than the LDA. Recommendation: The Institution should set up procedures to prevent future incidences and ensure compliance with 34 CFR 668.22(b)(1). The institution may want to consider changing either their absentee policy or their review of student attendance records once a student is close to violating their absentee policy. Views of Responsible Officials: Los Angeles Chapter National Tooling & Machining Association Training Center Trust dba NTMA Training Centers acknowledges this finding and will apply the recommendation.
Finding 2022-001 Packaging and Disbursing Pell Grant Noncompliance Criteria: A school must determine and calculate a student?s eligibility for a Federal Pell Grant during a payment period. To calculate the Federal Pell Grant award the school must use the payment and disbursement schedules published by the Secretary for each award year as per 34 CFR 690.62. Statement of Condition: The Federal Pell Grant amount disbursed does not match the Pell Chart based on the student?s Expected Family Contribution from the valid ISIR. Cause: The institution inadvertently used the wrong Pell Amount. Effect: In one (1) of forty-nine (49) original student files selected with a Federal Pell Grant disbursement, the Institution made a disbursement of Federal Pell Grant funds that was not calculated based upon the valid ISIR/Expected Family Contribution nor under the Federal Pell Grant Payment Schedule. Description of nature and extent of the issues reported: The sample student?s Federal Pell Grant fund was calculated, awarded, and disbursed inaccurately. Questioned cost: See Chart Recommendation: The Institution should set up procedures to prevent future incidences and ensure compliance with 34 CFR 690.62. Views of Responsible Officials: Los Angeles Chapter National Tooling & Machining Association Training Center Trust dba NTMA Training Centers acknowledges this finding and will apply the recommendation.
Finding 2022-003 Disbursing Funds for the Title IV Programs - Noncompliance Criteria: In accordance with 34 C.F.R. ?668.162 Requesting Funds, under the advanced payment method, an institution must disburse the funds requested as soon as administratively feasible but not later than three business days following the date the institution receives those funds. Statement of Condition: The disbursement of a Federal Pell Grant was made later than three business days after the institution received funds based on the G5 drawn down date. Cause: Unknown. Effect: In two (2) of 215 disbursements to students, the institution did not disburse a Federal Pell Grant within three business days following the date the institution received the funds. Description of nature and extent of the issues reported: The institution did not disburse Federal Pell Grant disbursements to the students within three business days after the institution received funds.
Finding 2022-005 Plus Notice Deficiencies - Noncompliance Criteria: Per 34 CFR 668.165, the Institution must notify the borrower in writing (paper or electronically) of the anticipated date and amount of the disbursement, student?s or parent?s right to cancel all or part of the loan or disbursement, and the procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the direct loan, loan disbursement. Statement of Condition: In four (4) of four (4) files tested with Parent Plus Loans, the Institution did not meet the requirements of notifications, per 34 CFR 668.165(a)(2)-(3) was deficient. In each case, the Instiutition sent one letter to the parent which included the total amount of the Plus loan approval for the entire period, vs. the disbursement amounts (by pay period with the anticipated date for each). The Institution has indicated that for each, a copy of the student?s notification was attached to the parent letters. Accepting this explanation of an attachment, the deficiencies are as follows: ? The parent borrower did not receive notification of the amount of and date for each disbursement. The letter that was provided to the parent was two pages. The first page included the total approved Plus amount (all payment periods), not the disbursement amount for the particular payment period and accordingly, the particular disbursement. The issue here is not gross vs. net considering fees but rather that the letter provided to each parent borrower was not based on individual disbursements but rather the Plus loan approval amount in aggregate. The second page was the notification addressed to the student for the first disbursement (this was not repeated with the second disbursement). The notification included an aggregate amount of all direct loans and did not specify the amount of the Plus loan. ? The parent did not receive a notification for each disbursement as the notification that was attached in each case, to the parent borrower letter, was at the time of the first disbursement. Three (3) of the four (4) students had two disbursements; no additional letter was sent to the parent at the time of the second notification. If a school does not obtain affirmative confirmation, a notification must be sent no earlier than 30 days before and no later than 7 days after crediting the student?s account. Notwithstanding the other deficiencies, the date of the letter does not meet the requirements of the date of the notification for each of the second disbursements. ? The parent did not receive a notification that informed the parent of the parent?s right to cancel. The notification that was attached to the aforementioned letter to the parent regarding the total approved Plus amount was addressed to the student and said ?you have the right to cancel??. There is no mention in the parent letter of attached notification that provides information about the parent?s right to cancel. Cause: Based on the views of the responsible officials to this finding, the cause appears to be a lack of understanding of the requirements. Management?s position is that the notification can be sent to either the parent OR the student and so they believe they have complied with the requirement. Effect: Notifications to parents were not sent which met both the language and timing regulations of Plus notifications. The parent may or may not have been aware of the disbursement amounts, disbursement dates, or the parent?s right to cancel. Description of nature and extent of the issues reported: Four students had plus loans provided by a parent borrower. A total of seven disbursements were made to the four students. Notification regulations in 34 CFR 668.165 (a) were not met in seven (7) of the seven (7) instances.
Finding 2022-002 Disbursement Reporting Requirements for the Title IV Programs - Material Weakness Criteria: In accordance with the requirements at 34 C.F.R. ?685.301(a)(2), a school must submit Direct Loan disbursement records, including the disbursement amount and disbursement date, as defined in 34 C.F.R.1649a), to COD. The most recent Federal Register notice specifies that a school must submit disbursement records no earlier than 7 days prior to the disbursement date and no later than 15 days after making the disbursement. The actual disbursement date is the date that the Direct Loan funds are made available to the borrower (i.e.: posting or crediting the funds to the student?s account). Because several terms and conditions of Direct Loans are tied to the actual disbursement date, this date must be accurately reported. Statement of Condition: The actual disbursement dates of Federal Pell Grant and Direct Loan funds were not reported to COD correctly. Cause: The institution did not update disbursement dates in EDExpress and therefore shows a discrepancy between the date of disbursement on the student?s ledger and the COD disbursement date. Per the institution, not changing the disbursement date in EDExpress was a training discrepancy that has been corrected. Effect: In eighty-two (82) of two hundred fifteen (215) disbursements to students including Federal Pell Grant and Direct Loan funds, the disbursement dates were not updated in COD. Description of nature and extent of the issues reported: The disbursement dates were incorrectly reported to COD for Federal Pell Grant and Direct Loan disbursements.
Finding 2022-004 Determine in a Timely Manner the Date of Withdrawal - Material Weakness Criteria: The date of the institution?s determination (DOD) that the student withdrew should be no later than 14 days after the student?s last date of attendance (LDA) as determined by the institution from its attendance records as per 34 CFR 668.22(b)(1). Statement of Condition: The Institution?s determination of the students? date of withdrawal was later than 14 days. Cause: The institution?s policy is that a student is terminated after 10 consecutive class day absences. The institution?s procedures include reviewing all attendance the subsequent business day. For example, a student who begins 10 consecutive absences on a Monday may complete 10 consecutive absences on a Friday. The institution?s procedure is to review Friday?s absences on a Monday. Effect: In five (5) of eighteen (18) drop students, the Institution?s determination of the date of withdrawals was later than 14 days. Description of nature and extent of the issues reported: The students? DODs were later than the required 14 days after the LDAs. Questioned cost: B9, B10, and B14 have DODs which are 17 days later than the LDAs. B15 has a DOD which is 20 days later than the LDA. B16 has a DOD which is 16 days later than the LDA. Recommendation: The Institution should set up procedures to prevent future incidences and ensure compliance with 34 CFR 668.22(b)(1). The institution may want to consider changing either their absentee policy or their review of student attendance records once a student is close to violating their absentee policy. Views of Responsible Officials: Los Angeles Chapter National Tooling & Machining Association Training Center Trust dba NTMA Training Centers acknowledges this finding and will apply the recommendation.
Finding 2022-002 Disbursement Reporting Requirements for the Title IV Programs - Material Weakness Criteria: In accordance with the requirements at 34 C.F.R. ?685.301(a)(2), a school must submit Direct Loan disbursement records, including the disbursement amount and disbursement date, as defined in 34 C.F.R.1649a), to COD. The most recent Federal Register notice specifies that a school must submit disbursement records no earlier than 7 days prior to the disbursement date and no later than 15 days after making the disbursement. The actual disbursement date is the date that the Direct Loan funds are made available to the borrower (i.e.: posting or crediting the funds to the student?s account). Because several terms and conditions of Direct Loans are tied to the actual disbursement date, this date must be accurately reported. Statement of Condition: The actual disbursement dates of Federal Pell Grant and Direct Loan funds were not reported to COD correctly. Cause: The institution did not update disbursement dates in EDExpress and therefore shows a discrepancy between the date of disbursement on the student?s ledger and the COD disbursement date. Per the institution, not changing the disbursement date in EDExpress was a training discrepancy that has been corrected. Effect: In eighty-two (82) of two hundred fifteen (215) disbursements to students including Federal Pell Grant and Direct Loan funds, the disbursement dates were not updated in COD. Description of nature and extent of the issues reported: The disbursement dates were incorrectly reported to COD for Federal Pell Grant and Direct Loan disbursements.
Finding 2022-004 Determine in a Timely Manner the Date of Withdrawal - Material Weakness Criteria: The date of the institution?s determination (DOD) that the student withdrew should be no later than 14 days after the student?s last date of attendance (LDA) as determined by the institution from its attendance records as per 34 CFR 668.22(b)(1). Statement of Condition: The Institution?s determination of the students? date of withdrawal was later than 14 days. Cause: The institution?s policy is that a student is terminated after 10 consecutive class day absences. The institution?s procedures include reviewing all attendance the subsequent business day. For example, a student who begins 10 consecutive absences on a Monday may complete 10 consecutive absences on a Friday. The institution?s procedure is to review Friday?s absences on a Monday. Effect: In five (5) of eighteen (18) drop students, the Institution?s determination of the date of withdrawals was later than 14 days. Description of nature and extent of the issues reported: The students? DODs were later than the required 14 days after the LDAs. Questioned cost: B9, B10, and B14 have DODs which are 17 days later than the LDAs. B15 has a DOD which is 20 days later than the LDA. B16 has a DOD which is 16 days later than the LDA. Recommendation: The Institution should set up procedures to prevent future incidences and ensure compliance with 34 CFR 668.22(b)(1). The institution may want to consider changing either their absentee policy or their review of student attendance records once a student is close to violating their absentee policy. Views of Responsible Officials: Los Angeles Chapter National Tooling & Machining Association Training Center Trust dba NTMA Training Centers acknowledges this finding and will apply the recommendation.