Criteria: Institutions must report all loan disbursements and submit required records to the Common Origination and Disbursement system (COD) within 15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Since up to three Direct Loan program years may be open at any given time, schools may receive three SAS data files each month (34 CFR 685.102(b), 685.301, and 303). Condition and Context: The College was unable to produce the reconciliations for review. Known Questioned Costs: None, reporting requirement not met. Cause: The College had turnover in the financial aid department where the responsibility for the reconciliations were not completed by the department. Effect: The College was out of compliance with the requirement to routinely reconcile its accounts with COD.Recommendation: The College should continue to implement procedures to ensure routine reconciliations with COD are performed as required. The College should also consider creating a training manual for any future new hires to learn the requirements related to federal aid scholarships.
Criteria: At minimum, schools are required to verify enrollment every 60 days. Condition and Context: The College did not report status changes for various students, primarily withdrawn students, within a timely manner as required. Known Questioned Costs: None, reporting requirement not met. Cause: The College reports status changes through the Registrar?s Office every 30 to 45 days. However, the Financial Aid Office did not reconcile with the Registrar?s Office during this time period which caused the College to not meet the timely requirements. Effect: The College was out of compliance with the requirement to report status changes in a timely manner. Recommendation: The College should implement policies to report status changes in students on a more frequent basis to ensure compliance with the reporting requirements. The College should also consider creating a training manual for any future new hires to learn the requirements related to federal aid scholarships.
Criteria: For students who participate in the direct loan program, the College is required to show evidence of exit counseling, or evidence that the College attempted to send counseling to the students. Condition and Context: The College could not produce support showing completed exit counseling or proof of an attempt to send exit counseling for 19 students that graduated/withdrew out of 40 students tested. Known Questioned Costs: None, noncompliance related to additional requirements of the Direct Loan program. Cause: The College did not keep record of exit counseling being sent to students that graduated/withdrew. Effect: The College was out of compliance with the additional compliance requirement of the Direct Loan program. Recommendation: The College should implement policies to retain records relating to the sending of exit counseling to students that graduated/withdrew.
Criteria: 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 668.164(i)). There are two exceptions to this rule. First, institutions may not disburse or deliver the first installment of Direct Loans to first-year undergraduates who are first time borrowers until 30 days after the student?s first day of classes (34 CFR 668.164(i)(2)), unless the institution has low default rates. Condition and Context: The College disbursed funds within 30 days of the first day of class for 12 first year students out of 40 students tested. Known Questioned Costs: $124,924 Cause: Disbursements of federal aid was processed at a similar timeframe for all students, regardless of first- or second-year status. Effect: The College was out of compliance with the requirement to withhold funds for true first year students for the first 30 days after the first day of class. Recommendation: The College should ensure policies exist to withhold funds for the first 30 days of classes for true first year students. The College should also consider creating a training manual for any future new hires to learn the requirements related to federal aid scholarships.
Criteria: To have students be eligible for Title IV funds, a student must make satisfactory academic progress, and the School must have a reasonable policy for monitoring that progress. Condition and Context: The College disbursed funds to one student out of 40 students tested who did not comply with the satisfactory eligibility progress policy set forth by the College. Known Questioned Costs: $6,573 Cause: The College did not monitor the student's GPA prior to federal aid disbursement. Effect: The College was out of compliance with the requirement that federal aid of Title IV funds be disbursed to students making satisfactory academic progress. Recommendation: The College should implement a tracking or review system to ensure all monies are disbursed to students who are meeting satisfactory academic policies set forth by the College.
Criteria: Institutions must report all loan disbursements and submit required records to the Common Origination and Disbursement system (COD) within 15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Since up to three Direct Loan program years may be open at any given time, schools may receive three SAS data files each month (34 CFR 685.102(b), 685.301, and 303). Condition and Context: The College was unable to produce the reconciliations for review. Known Questioned Costs: None, reporting requirement not met. Cause: The College had turnover in the financial aid department where the responsibility for the reconciliations were not completed by the department. Effect: The College was out of compliance with the requirement to routinely reconcile its accounts with COD.Recommendation: The College should continue to implement procedures to ensure routine reconciliations with COD are performed as required. The College should also consider creating a training manual for any future new hires to learn the requirements related to federal aid scholarships.
Criteria: At minimum, schools are required to verify enrollment every 60 days. Condition and Context: The College did not report status changes for various students, primarily withdrawn students, within a timely manner as required. Known Questioned Costs: None, reporting requirement not met. Cause: The College reports status changes through the Registrar?s Office every 30 to 45 days. However, the Financial Aid Office did not reconcile with the Registrar?s Office during this time period which caused the College to not meet the timely requirements. Effect: The College was out of compliance with the requirement to report status changes in a timely manner. Recommendation: The College should implement policies to report status changes in students on a more frequent basis to ensure compliance with the reporting requirements. The College should also consider creating a training manual for any future new hires to learn the requirements related to federal aid scholarships.
Criteria: For students who participate in the direct loan program, the College is required to show evidence of exit counseling, or evidence that the College attempted to send counseling to the students. Condition and Context: The College could not produce support showing completed exit counseling or proof of an attempt to send exit counseling for 19 students that graduated/withdrew out of 40 students tested. Known Questioned Costs: None, noncompliance related to additional requirements of the Direct Loan program. Cause: The College did not keep record of exit counseling being sent to students that graduated/withdrew. Effect: The College was out of compliance with the additional compliance requirement of the Direct Loan program. Recommendation: The College should implement policies to retain records relating to the sending of exit counseling to students that graduated/withdrew.
Criteria: 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 668.164(i)). There are two exceptions to this rule. First, institutions may not disburse or deliver the first installment of Direct Loans to first-year undergraduates who are first time borrowers until 30 days after the student?s first day of classes (34 CFR 668.164(i)(2)), unless the institution has low default rates. Condition and Context: The College disbursed funds within 30 days of the first day of class for 12 first year students out of 40 students tested. Known Questioned Costs: $124,924 Cause: Disbursements of federal aid was processed at a similar timeframe for all students, regardless of first- or second-year status. Effect: The College was out of compliance with the requirement to withhold funds for true first year students for the first 30 days after the first day of class. Recommendation: The College should ensure policies exist to withhold funds for the first 30 days of classes for true first year students. The College should also consider creating a training manual for any future new hires to learn the requirements related to federal aid scholarships.
Criteria: To have students be eligible for Title IV funds, a student must make satisfactory academic progress, and the School must have a reasonable policy for monitoring that progress. Condition and Context: The College disbursed funds to one student out of 40 students tested who did not comply with the satisfactory eligibility progress policy set forth by the College. Known Questioned Costs: $6,573 Cause: The College did not monitor the student's GPA prior to federal aid disbursement. Effect: The College was out of compliance with the requirement that federal aid of Title IV funds be disbursed to students making satisfactory academic progress. Recommendation: The College should implement a tracking or review system to ensure all monies are disbursed to students who are meeting satisfactory academic policies set forth by the College.