Corrective Action Plans

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Corrective Action Planned: The process for disbursement notification will be reviewed. Features of the student information system will be utilized so that the new notification will include specific details of the amount and type of Title IV funds, as well as in formation regarding the right to cance...
Corrective Action Planned: The process for disbursement notification will be reviewed. Features of the student information system will be utilized so that the new notification will include specific details of the amount and type of Title IV funds, as well as in formation regarding the right to cancel any portion of loans to be distributed. Name(s) of Contact Person(s) Responsible for Corrective Action: Doug Watson, Financial Aid Director & Joseph Harnisch, CFO Anticipated Completion Date: The Corrective Action was completed on August 16, 2024.
Finding 525614 (2024-005)
Significant Deficiency 2024
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timefr...
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR Section 685.309(b)(2), the University is responsible for notifying the National Student Loan Data System (NSLDS) of changes to student’s enrollment data within minimum required timeframes. Cause: Controls are not functioning properly. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the withdrawal date was incorrectly reported as the last day of the term for four students and was not reported for one student. In addition, the R2T4 calculation was prepared untimely for four students that required a calculation, as noted in finding 2024-004, and thus the withdrawal dates were reported untimely. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend that a review process be put in place to ensure timely and accurate enrollment reporting to NSLDS. Corrective Actions: The policy to be developed regarding student withdrawals and R2T4 calculations will specify that students’ withdrawal dates are to be defined as the last date of academic attendance. The policy also will stipulate that, in accordance with National Student Clearinghouse requirements, Bluefield University will submit accurate student enrollment data throughout the academic year.
Finding 525613 (2024-004)
Significant Deficiency 2024
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency) Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determina...
U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency) Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determination. Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Cause: Controls are not functioning properly. Effect: Funds were not timely returned to students or federal agencies as required. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the R2T4 calculations were required for nine students. Of the nine students, R2T4 calculations were prepared untimely for six students, resulting in a late return of Title IV funds. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination. Corrective Actions: In February 2025, Bluefield University leadership will work with the combined staff of the University’s Bluefield Central one-stop administrative office to develop and document a policy to ensure that communication from the registrar’s office regarding a student’s official or unofficial withdrawal occurs within 15 days of the student’s withdrawal. The policy also will stipulate that the financial aid staff of Bluefield Central will complete R2T4 calculations within 30 days of the student’s withdrawal, and the University’s business office will return Title IV funds to the Department of Education within 40 days of a student’s withdrawal.
Description of Finding: From the testing sample 3 instances were found where student financial aid was incorrectly packaged. All 3 were under awarded loans and or Pell Grants. Statement of Concurrence or Nonconcurrence: Management agrees that in each of the 3 cases, aid was not packaged correctly. C...
Description of Finding: From the testing sample 3 instances were found where student financial aid was incorrectly packaged. All 3 were under awarded loans and or Pell Grants. Statement of Concurrence or Nonconcurrence: Management agrees that in each of the 3 cases, aid was not packaged correctly. Corrective Action: The staff in the financial assistance office has seen a large turnover over the past year. Training continues for those new to packaging. A Pell Report has been developed to automatically identify Pell awards based on the new SAI process. Summer Pell training for eligible students will be held for all staff before the Summer 2025 award period. Name of Contact Person: Dyllon Harper, Director of Financial Assistance, Projected Completion Date: Summer 2025
Description of Finding: From the testing sample, six instances were found where credit balances from Title IV balances were not properly refunded to students based on the disbursement dates. Statement of Concurrence or Nonconcurrence: With staff turnover, offices were incurring a longer time to bala...
Description of Finding: From the testing sample, six instances were found where credit balances from Title IV balances were not properly refunded to students based on the disbursement dates. Statement of Concurrence or Nonconcurrence: With staff turnover, offices were incurring a longer time to balance COD approved disbursements to actual disbursements to student accounts. Once the loan disbursements were balanced and confirmed to students, the loan refunds were immediately released to students. CMU is aware of, and normally follows the 14 day policy, but it was determined to hold loan refunds until the loans posted to CMU accounts were correct with COD to avoid incorrect disbursements. Corrective Action: The office of Financial Assistance has identified balancing COD disbursements and internal loan disbursement as a mandatory priority each week. A macro report has been developed to help identify differences with COD and allow corrections and COD draws in a timely fashion. Name of Contact Person: Dyllon Harper, Director of Financial Assistance, Projected Completion Date: Fall 2024
Finding 525598 (2024-001)
Significant Deficiency 2024
Criteria, Condition, Cause: We concur that our timely reporting of academically dismissed students during the non-required summer term is an issue and will be vigilant to prevent this delayed reporting in the fun1re. It should be noted that this small cohort was all deemed ineligible to return for ...
Criteria, Condition, Cause: We concur that our timely reporting of academically dismissed students during the non-required summer term is an issue and will be vigilant to prevent this delayed reporting in the fun1re. It should be noted that this small cohort was all deemed ineligible to return for the upcoming semester on the same day, and so that singular days' enrollment status changes were the only updates that were untimely in the submission to the National Student Loan Data System (NSLDS). We will be modifying and monitoring our process to accurately capture and report to the NSLDS sh1dents determined to be ineligible to return in the fall semester even during a tenn of non-required enrollment. Effect, Questioned costs, Context: Enrollment rosters and updated enrollment statuses are reported regularly with NSLDS to ensure current enrollment status that can impact loan repayment dates and in-school deferments are accurately on record with the Department of Education. For the summer enrollment roster, although Allegheny's summer term is a non-required tern1, students that are not enrolled in the summer tern1, but Allegheny is aware that they will not be enrolled in the upcoming required fall tem1 must be reported as withdrawn through the summer enrollment roster. Recommendation The College will continue to confom1 to the NSLDS reporting process and timeline, and with the collaboration of the Financial Aid's, Registrar's, and Provost's Offices, will fully bring the non-required term enrollment reporting into alignment. For the next non-required summer tern1 enrollment report in 2025, Allegheny will be incorporating the shtdents determined to be academically dismissed from the spring tenn on the initial summer enrollment roster with the updated withdrawn stah1s. The initial summer enrollment roster will be submitted within 60 days.
Finding 525559 (2024-004)
Significant Deficiency 2024
Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkin...
Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkins section of the FISAP for the next reporting year. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Finding 525556 (2024-003)
Significant Deficiency 2024
Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Conta...
Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Finding 525554 (2024-001)
Significant Deficiency 2024
Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: Febru...
Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Finding 525538 (2024-001)
Significant Deficiency 2024
Return of Title IV (R2T4) Planned Corrective Action: The College will continue to ensure that the Financial Aid staff is properly and regularly trained on all aspects of Return of Title IV Funds. The staff will participate in any webinars or conferences available. Weekly reports will be produced ...
Return of Title IV (R2T4) Planned Corrective Action: The College will continue to ensure that the Financial Aid staff is properly and regularly trained on all aspects of Return of Title IV Funds. The staff will participate in any webinars or conferences available. Weekly reports will be produced to ensure that all calculations are completed within the 45-day regulation. The Director of Financial Aid will regularly review calculations for accuracy, completeness, and timely return of funds. Person Responsible for Corrective Action Plan: Monique Rickenbaker, Director of Financial Aid and Scholarships Anticipated Date of Completion: July 1, 2025
Finding Number: 2024-001 Condition: The University did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: To address the root cause of the enrollment reporting error, which stemmed from turnover in the registrar’s office during ...
Finding Number: 2024-001 Condition: The University did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: To address the root cause of the enrollment reporting error, which stemmed from turnover in the registrar’s office during Spring 2024 and resulted in an oversight of unofficial withdrawals reported to the Clearinghouse/NSLDS until identified during the audit, a comprehensive corrective action plan has been developed. Our institution is implementing a new ERP system, we will automate enrollment reporting to ensure timely and accurate data submission. Additional staff will be recruited and trained, with cross-training programs to mitigate turnover impact. Regular internal audits will ensure compliance. Improved communication and coordination will enable continuous monitoring to improve overall efficiency and accuracy. Contact person responsible for corrective action: N. Chad Curley Anticipated Completion Date: 09/01/2024
American Baptist College does not dispute this finding. It is the College’s policy to submit all records/documentation by published due dates. To do so, however, the College must have qualified employees to carry out stated requirements. Since July 2024 the College has published a job opening for th...
American Baptist College does not dispute this finding. It is the College’s policy to submit all records/documentation by published due dates. To do so, however, the College must have qualified employees to carry out stated requirements. Since July 2024 the College has published a job opening for the Director of Financial Aid but has been unable to fill the position due to limited resources. The College is currently working with a consulting firm to provide financial aid services to the student body and will publish the job position until it is filled.
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (...
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Illinois Wesleyan University will designate an individual to be the Information Security Officer. The information security policy will be updated as applicable for GLBA standards. Name(s) of the contact person(s) responsible for corrective action: David Myron, Vice President of Business and Finance Planned completion date for corrective action plan: Updates for the information security policy will be made on an as-needed basis for applicable changes. The Information Security Officer was named in Spring 2024 and has continued progress forward for GLBA compliance.
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (...
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When a graduation has been confirmed outside of the normal timeframe due to later grade reporting, the Assistant Registrar will include the Director of Financial Aid and the Associate Director of Financial Aid in an email along with the standard process of notifying the Associate Registrar. The Associate Director of Financial Aid will go directly to NSLDS and enter the graduation date in NSLDS. The Associate Registrar will continue the normal reporting process with the Clearinghouse but this will alleviate challenges that come when the Associate Registrar is resolving discrepancies and can’t report the graduation immediately. Name(s) of the contact person(s) responsible for corrective action: Scott Seibring, Director of Financial Aid Planned completion date for corrective action plan: This process will be implemented starting with the Spring 2025 semester.
Return of Title IV (R2T4) Returning of Funds Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268 Recommendation: We recommend the University review its procedures to ensure that title IV funds required to be returned are done so within 45 days after the date of the...
Return of Title IV (R2T4) Returning of Funds Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268 Recommendation: We recommend the University review its procedures to ensure that title IV funds required to be returned are done so within 45 days after the date of the institution's determination that the student withdrew. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We did a thorough review of the findings, including in depth discussions with our audit firm to understand the details of the findings and to ascertain their root cause. We have provided training for staff on appropriate processing of Return of Title IV Funds. Name(s) of the contact person(s) responsible for corrective action: Eulanie Morales, Director of Financial Aid. Planned completion date for corrective action plan: January 31, 2025.
NSLDS Enrollment Reporting Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. ...
NSLDS Enrollment Reporting Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We did a thorough review of the findings, including in depth discussions with our audit firm to understand the details of the findings and to ascertain their root cause. The actions we took last year reduced the incidence rate, but we have more work to do. In addition to continued engagement with NSC, we have engaged with our IT Department – they will assist the Registrar’s office in engaging our Student Information System vendor to improve the accuracy of the data files that we transmit to NSC. We also engaged a consultant to provide us with training and to help us improve processes and reporting time. Name(s) of the contact person(s) responsible for corrective action: Robert Boggs, EdD, University Registrar. Planned completion date for corrective action plan: April 30, 2025.
Finding 2024-005 Recommendation: The University should implement a monthly review process to ensure all student enrollment status changes are captured when certifying enrollment data. View of Responsible Officials and Planned Corrective Actions: During fiscal year 2024, there was a one-time error re...
Finding 2024-005 Recommendation: The University should implement a monthly review process to ensure all student enrollment status changes are captured when certifying enrollment data. View of Responsible Officials and Planned Corrective Actions: During fiscal year 2024, there was a one-time error resulting in manual enrollment statuses not being captured by the National Student Clearinghouse (NSC). Degree and enrollment files were sent timely, however, manual updates of student statuses on the NSC website were not processed successfully leading to inconsistencies. Going forward, enrollment files will be reviewed regularly against the NSLDS website to ensure that all student enrollment statuses are accurate. Individual Responsible for Corrective Action: Deanna Carroll, University Registrar, 610-660-1000, ddaly@sju.edu Anticipated Completion Date for Corrective Action: The Planned Corrective Actions will be immediately implemented.
Finding 2024-004 Recommendation: The University should evaluate all program lengths per the website and ensure that program lengths are accurate and that there are no discrepancies when comparing the website to NSLDS. View of Responsible Officials and Planned Corrective Actions: The University will ...
Finding 2024-004 Recommendation: The University should evaluate all program lengths per the website and ensure that program lengths are accurate and that there are no discrepancies when comparing the website to NSLDS. View of Responsible Officials and Planned Corrective Actions: The University will immediately review all program lengths and update the website as well as Banner. Moving forward, Banner will be the system of record for program lengths and basis for reporting to the NSLDS. Any updates or changes to the website will require approval from the Registrar and Financial Aid Offices to ensure that all records are consistent and accurate. Individual Responsible for Corrective Action: Deanna Carroll, University Registrar, 610-660-1000, ddaly@sju.edu Anticipated Completion Date for Corrective Action: The Planned Corrective Actions will be immediately implemented.
Finding 2024-003 Recommendation: The University should implement a control within the Financial Aid department that requires another individual within the department to review the Pell funds awarded by student for accuracy. For the 13 students with inaccurate Pell awards, these were corrected immedi...
Finding 2024-003 Recommendation: The University should implement a control within the Financial Aid department that requires another individual within the department to review the Pell funds awarded by student for accuracy. For the 13 students with inaccurate Pell awards, these were corrected immediately when brought to management’s attention. View of Responsible Officials and Planned Corrective Actions: This issue was unique to the 2023 summer term as a result of the University changing the header semester to the summer term for the 23/24 award year. The University has changed the fund award and disbursement schedule rules in Banner to correctly calculate the Pell Grant awards for summer terms. This eliminates the need for Financial Aid staff to manually update awards on an individual student basis. In addition to the aforementioned change in the Banner rules, the University will have an individual in the Financial Aid Office run a report to audit summer term awards to ensure the Pell Grant is being calculated correctly. Individual Responsible for Corrective Action: Caroline Baker, Senior Director of Financial Aid, 610-660-1000, cbaker01@sju.edu Anticipated Completion Date for Corrective Action: The Planned Corrective Actions will be immediately implemented.
The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized t...
The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals, exit counseling communications and FDL and Pell reconciliations are done monthly going forward. Both the FDL and Pell programs were closed out timely for 2023-2024.
The University identified certain automated COD communication and reporting rules in our Student Information System (SIS) that were not working properly during the 2023-2024 aid year. The breakdown of these automated rules required manual interventions to have all FDL and Pell disbursements reported...
The University identified certain automated COD communication and reporting rules in our Student Information System (SIS) that were not working properly during the 2023-2024 aid year. The breakdown of these automated rules required manual interventions to have all FDL and Pell disbursements reported to COD. Due to significant staffing turnover in the financial aid department and the manual interventions needed, not all reporting was able to be completed within 15 days. The University has since hired an expert directly from our SIS company to evaluate and fix all malfunctioning rules so that manual intervention is not required going forward.
The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized t...
The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done monthly going forward.
The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized t...
The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done monthly going forward.
This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing ou...
This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the set-up and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. Since implementing the new system, Union has submitted our Enrollment Reporting Roster on a regular and timely basis. Under NSC, our submissions have occurred at least once per month and within the 15-day reporting requirement. As a result, we do not anticipate late reporting of Enrollment Reporting Rosters for FY25 or future periods.. Accuracy of Enrollment Status Changes: In order to further improve the timeliness and accuracy of our enrollment report submissions, we plan to make the following changes to our process with NSC. First, we will schedule additional submissions of our Enrollment Roster at key points during the academic year: (1) prior to the start of each semester, (2) immediately after the end of the drop-add period, and (3) during our non-required summer term. Second, we will work with NSC on our system configuration and error correction process, to ensure that enrollment status is accurately reported and that all status errors are resolved correctly and in a timely manner. Enrollment Roster transmissions will continue to take place according to a preset schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission, and notification of potential errors. Union’s Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office, and IT Department to ensure that all student records accurately and correctly configured.
The College, upon identification of this issue, recalculated the Pell Grant awards and disbursed the eligible amounts to the 4 students. The College also conducted an internal review of students whose payment period was 3 trimesters based on expected enrollment and identified two additional students...
The College, upon identification of this issue, recalculated the Pell Grant awards and disbursed the eligible amounts to the 4 students. The College also conducted an internal review of students whose payment period was 3 trimesters based on expected enrollment and identified two additional students who only attended the first 2 of the three trimesters; the College recalculated and disbursed the eligible amounts to these two students. Additionally, the College immediately reviewed its procedures and made necessary changes.
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