Federal Program Information: Federal Perkins Loan Program (ALN #84.038) Criteria or Specific Requirement: Special Tests and Provisions ? Perkins Loan Recordkeeping and Record Retention - Institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made, in a locked, fireproof container. (34 CFR 674.19.(e)) Condition: Instances where the University did not retain the original or true and exact copies of promissory notes. Cause: Lack of administrative oversight with respect to recordkeeping and record retention related to the Federal Perkins Loan program (?Perkins?), including improper tracking and storage of records. Effect or Potential Effect: The University was not in compliance with the Perkins loan recordkeeping and record retention requirements. Questioned Costs: None. Context: For 4 of 25 borrowers with open loans selected for testing, the University did not retain an original or true and exact copy of the promissory note. For 3 of 25 borrowers with retired loans within the previous three fiscal years and current fiscal year, the University did not retain the appropriate records. Identification as a Repeat Finding: There was no similar finding in the prior year. Recommendation: We recommend the University retain the appropriate records for the required timeframe. We also recommend a full review of records on-hand. Views of Responsible Officials: The Policy and Procedures manual has been updated to reflect this process. The Business Office has implemented measures to ensure that Perkins Promissory Notes are identified, stored, and accessible during their repayment and collection period. In addition to the current filing system, the Business Office will utilize management software for ease of access and recording. To ensure that all remaining promissory notes are kept in accordance with Department of Education regulations, the Business Office will: ? Record all incoming promissory notes internally and externally. ? Promissory notes created prior to 2013 will be made digitally accessible through Perceptive Content, a secure content management system. Access to these promissory notes will only be accessible by parties with authorized access. ? Promissory notes created after 2013 will continue to be made available through Heartland ECSI?s third party filing system. ECSI records paid, completed, cancelled, and retired promissory notes that were created after 2013. ? In accordance with the Perkins Assignment and Liquidation Guide from the Department of Education (EA ID: General-21-53), all accounts with promissory notes unable to be located will be written off and/or purchased from the Department of Education prior to the end of FY 2023.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instances where the University did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students, including inadequate review and tracking of refunds due. Effect or Potential Effect: The University was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 2 of 25 students selected for testing, the University did not issue the refund within the required 14 days. Identification as a Repeat Finding: There was no similar finding in the prior year. Recommendation: We recommend the University complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. We also recommend timely review of refunds due. Views of Responsible Officials: The Policy and Procedures manual has been updated to reflect the following updated process: The Business Office processes student refunds within 14 days after a Title IV credit balance appears on a student?s account. At least once per week, the Refunds Coordinator generates a refund report (ARTM) which lists students with credit balances. The University?s policy is that all refunds are processed via ACH (direct deposit), and all students are required to provide their bank account information. Communication is sent to students throughout the semester reminding them to sign up for direct deposit. To ensure that all students receive their refunds by the required 14 days, a paper check is issued to students missing banking information. Checks are sent to the mailing address on file. Communication will continue to be sent to all students encouraging them to sign up for ACH refunds. However, refunds are processed timely even if the banking information is not available.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement: Special Tests and Provisions ? Disbursements To or On Behalf of Students - Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution 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 or the TEACH Grant payments returned to the U.S. Department of Education; 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 (as described in 34 CFR section 668.165 (a)(6)(i)) 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 or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Instances were identified where the required loan disbursement notifications were not sent to the student or parent. Cause: Lack of administrative oversight and insufficient internal control over compliance with respect to loan disbursement notification requirements, including untimely review of notification logs. Effect or Potential Effect: Students and/or parents were not notified of award disbursements and/or their right to cancel/decline loan awards in a timely manner. Questioned Costs: None. Context: For 25 of 25 students selected for testing, the University did not send the required loan disbursement notifications to borrowers. Identification as a Repeat Finding: There was no similar finding in the prior year. Recommendation: We recommend the University enhance its policies, procedures and internal control over compliance with award notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. We also recommend timely review of notification logs and retention of proper documentation. Views of Responsible Officials: The Policy and Procedures manual has been updated to reflect the following updated process: The Financial Aid Office has implemented measures to ensure students/parents that have Title IV loans disbursed are sent loan disbursement notifications via Colleague once a loan disbursement has been made. The process is done via Colleague each day and captures all Title IV loan disbursements made for the previous day. The notifications are processed via the ST-PCB process in Colleague, which sends a system generated loan disbursement notification to the student/parent. Processes are being worked on with the Information Technology department to generate a copy of the notification and to put in place a paper notification if no parent email is provided.
Federal Program Information: Federal Perkins Loan Program (ALN #84.038) Criteria or Specific Requirement: Special Tests and Provisions ? Perkins Loan Recordkeeping and Record Retention - Institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made, in a locked, fireproof container. (34 CFR 674.19.(e)) Condition: Instances where the University did not retain the original or true and exact copies of promissory notes. Cause: Lack of administrative oversight with respect to recordkeeping and record retention related to the Federal Perkins Loan program (?Perkins?), including improper tracking and storage of records. Effect or Potential Effect: The University was not in compliance with the Perkins loan recordkeeping and record retention requirements. Questioned Costs: None. Context: For 4 of 25 borrowers with open loans selected for testing, the University did not retain an original or true and exact copy of the promissory note. For 3 of 25 borrowers with retired loans within the previous three fiscal years and current fiscal year, the University did not retain the appropriate records. Identification as a Repeat Finding: There was no similar finding in the prior year. Recommendation: We recommend the University retain the appropriate records for the required timeframe. We also recommend a full review of records on-hand. Views of Responsible Officials: The Policy and Procedures manual has been updated to reflect this process. The Business Office has implemented measures to ensure that Perkins Promissory Notes are identified, stored, and accessible during their repayment and collection period. In addition to the current filing system, the Business Office will utilize management software for ease of access and recording. To ensure that all remaining promissory notes are kept in accordance with Department of Education regulations, the Business Office will: ? Record all incoming promissory notes internally and externally. ? Promissory notes created prior to 2013 will be made digitally accessible through Perceptive Content, a secure content management system. Access to these promissory notes will only be accessible by parties with authorized access. ? Promissory notes created after 2013 will continue to be made available through Heartland ECSI?s third party filing system. ECSI records paid, completed, cancelled, and retired promissory notes that were created after 2013. ? In accordance with the Perkins Assignment and Liquidation Guide from the Department of Education (EA ID: General-21-53), all accounts with promissory notes unable to be located will be written off and/or purchased from the Department of Education prior to the end of FY 2023.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Federal Student Aid (?FSA?) Credit Balances - Where disbursements created a credit balance in the student account and the student or parent did not provide an authorization for the institution to retain funds, the institution must provide the credit balance amount to the student within 14 days of the date the balance was created (34 CFR 668.164(h)). Condition: Instances where the University did not issue a refund within the required timeframe. Cause: Lack of administrative oversight with respect to disbursements to or on behalf of students, including inadequate review and tracking of refunds due. Effect or Potential Effect: The University was not in compliance with disbursements to or on behalf of students. Questioned Costs: None. Context: For 2 of 25 students selected for testing, the University did not issue the refund within the required 14 days. Identification as a Repeat Finding: There was no similar finding in the prior year. Recommendation: We recommend the University complete a timely review of credit balances in order to issue all refunds with respect to FSA credit balances within the required timeframe. We also recommend timely review of refunds due. Views of Responsible Officials: The Policy and Procedures manual has been updated to reflect the following updated process: The Business Office processes student refunds within 14 days after a Title IV credit balance appears on a student?s account. At least once per week, the Refunds Coordinator generates a refund report (ARTM) which lists students with credit balances. The University?s policy is that all refunds are processed via ACH (direct deposit), and all students are required to provide their bank account information. Communication is sent to students throughout the semester reminding them to sign up for direct deposit. To ensure that all students receive their refunds by the required 14 days, a paper check is issued to students missing banking information. Checks are sent to the mailing address on file. Communication will continue to be sent to all students encouraging them to sign up for ACH refunds. However, refunds are processed timely even if the banking information is not available.
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement: Special Tests and Provisions ? Disbursements To or On Behalf of Students - Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution 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 or the TEACH Grant payments returned to the U.S. Department of Education; 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 (as described in 34 CFR section 668.165 (a)(6)(i)) 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 or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Instances were identified where the required loan disbursement notifications were not sent to the student or parent. Cause: Lack of administrative oversight and insufficient internal control over compliance with respect to loan disbursement notification requirements, including untimely review of notification logs. Effect or Potential Effect: Students and/or parents were not notified of award disbursements and/or their right to cancel/decline loan awards in a timely manner. Questioned Costs: None. Context: For 25 of 25 students selected for testing, the University did not send the required loan disbursement notifications to borrowers. Identification as a Repeat Finding: There was no similar finding in the prior year. Recommendation: We recommend the University enhance its policies, procedures and internal control over compliance with award notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. We also recommend timely review of notification logs and retention of proper documentation. Views of Responsible Officials: The Policy and Procedures manual has been updated to reflect the following updated process: The Financial Aid Office has implemented measures to ensure students/parents that have Title IV loans disbursed are sent loan disbursement notifications via Colleague once a loan disbursement has been made. The process is done via Colleague each day and captures all Title IV loan disbursements made for the previous day. The notifications are processed via the ST-PCB process in Colleague, which sends a system generated loan disbursement notification to the student/parent. Processes are being worked on with the Information Technology department to generate a copy of the notification and to put in place a paper notification if no parent email is provided.