Finding FA 2024-002: Special Tests and Provisions: Return of Title IV Funds: Incorrect Calculation of Return of Title IV Funds; and Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) (Repeat Finding)
Federal Program Information:
Assistance Listing Number: ALN 84.063 and 84.268
Federal Program Name: Student Financial Assistance Cluster;
Federal Pell Grant Program
Federal Direct Student Loans
Federal Agency: U.S. Department of Education
Passed Through Entity: N/A
Federal Award Number: P063P210033; P063P215263; P063P210034; P063P210658;
P063P210035; P063P215261; P063P215260; P063P210036;
P063P215262; P268K220033; P268K225263; P268K220034;
P268K220658; P268K220035; P268K225261; P268K225260;
P268K220036; P268K225262
Federal Award Year: July 1, 2023, to June 30, 2024
Campuses: Los Angeles City College (Repeat Finding)
East Los Angeles College (Repeat Finding)
Los Angeles Harbor College (Repeat Finding)
Los Angeles Mission College (Repeat Finding)
Los Angeles Pierce College (Repeat Finding)
Los Angeles Southwest College (Repeat Finding)
Los Angeles Trade Technical College (Repeat Finding)
Los Angeles Valley College (Repeat Finding)
West Los Angeles College (Repeat Finding)
Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds
Criteria or Specific Requirement:
Per 34 Code of Federal Regulations:
34 CFR 668.22(a) When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement.
34 CFR 668.22(b) Withdrawal date for a student who withdraws from an institution that is required to take attendance: “(1).the student’s withdrawal date is the last date of academic attendance as determined by theinstitution from its attendance records. (2) An institution must document a student’s withdrawal date and maintain the documentation as of the date of the institution’s determination that the student withdrew.”
34 CFR668.22 (c) Withdrawal date for a student who withdraws from an institution that is not required to take attendance.) “(1)..a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the
mid-point of the payment period (or period of enrollment, if applicable); (iv) If the institution determines that a student did not begin the institution’s withdrawal process or otherwise provide official notification (including notice from an individual acting on the student’s behalf) to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student’s control, the date that the institution determines is related to that circumstance; (v) If a student does not return from an approved leave of absence as defined in paragraph (d) of this section, the date that the institution determines the student began the leave of absence; or (vi) If a student takes a leave of
absence that does not meet the requirements of paragraph (d) of this section, the date that the student began the leave of absence. (2) An institution that is not required to take attendance may use as the student’s withdrawal date a student’s last date of attendance at an academically related activity provided that the institution documents that the activity is academically related and documents the student’s attendance at the activity. (3) An institution must document a student’s withdrawal date and maintain the documentation as of the date of the institution’s determination that the student withdrew.
Per OMB Compliance Supplement:
Title IV funds may be expended only towards the education of the students who can be proven to have been in attendance at the institution. In a distance education context, documenting that a student has logged into an online distance education platform system is not sufficient, by itself, to demonstrate attendance by the student. To avoid returning all funds for a student that did not begin attendance, an institution must be able to document “attendance at any class.” To qualify as a last date of attendance for Return of Title IV purposes, an institution must demonstrate that a student participated in class or was otherwise engaged in an academically related activity, such as by contributing to an online discussion or
initiating contact with a faculty member to ask a course-related question. Per the Department of Education’s Program Integrity Q&As for Return of Title IV Funds: An Institution that is required to take attendance: An institution that collects and maintains information about students’ online activities for the purpose of tracking academic engagement is considered to be an institution that is required to take attendance for programs involving such tracking if that tracking: 1. Involves monitoring student attendance in a synchronous class, lecture, recitation, or field or laboratory
activity, physically or online via a distance education platform, where there is an opportunity for interaction between the instructor and students; or
2. Is used to administratively withdraw students or to enforce an institutional attendance policy.
Identified Condition:
A. Incorrect Calculation of Return of Title IV Funds
Los Angeles Harbor College
B. Distance Education (DE) Courses – Implementation of Formal Process to
Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP)
Los Angeles City College
East Los Angeles College
Los Angeles Harbor College
Los Angeles Mission College
Los Angeles Pierce College
Los Angeles Southwest College
Los Angeles Trade Technical College
Los Angeles Valley College
West Los Angeles College
Description
A. Incorrect Calculation of Return of Title IV Funds
Los Angeles Harbor College
We noted 2 of 20 students selected for return to Title IV funds testwork from the population of students who had withdrawn, dropped out, or never began attendance for Fall 2023 that had an incorrect calculation of return of Title IV amounts. The students had a reduction in eligible Title IV grant aid for $1,335 and $2,304, respectively, but the District did not recalculate the student and campus return of Title IV amounts based on
the updated eligible Title IV grant aid amount. For these 2 students, such error resulted in:
• 1 student with an understatement of institutional return of $119 and an understatement of student
return of $104. The effect of the understatement did not result in questioned costs due to grant
protection.
• 1 student with an understatement of student return of $230 after the grant protection is applied.
B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP)
In assessing the District's CAP for prior year finding FA 2023-002, we noted that during Fall 2023, the District implemented a formal process to monitor a student's active participation in an online class and engagement in academic activities related to a distance education (DE) course in order to determine the reasonableness and accuracy of a student's withdrawal date in the Student Information System (SIS). There are two types of withdrawals for DE courses: student-initiated withdrawals and instructor-initiated withdrawals. For student-initiated withdrawals, the withdrawal date used in the calculation of return of Title IV funds is the date the student initiates the withdrawal from the course in the system. For instructorinitiated withdrawals, the District implemented formal procedures beginning in Fall 2023 whereby the instructor is responsible for reviewing student rosters for DE courses at scheduled intervals (census roster date, exclusion roster date, and active enrollment roster date) throughout the term. At these scheduled interval dates, the instructor must initiate a withdrawal for a student who is deemed to no longer be academically engaged, as determined by the instructor. Additionally, the District's Internal Audit Department began conducting reviews of the instructor's data entry related to student withdrawal dates for DE courses into the SIS beginning in November 2023. During the current year, the Internal Audit Department conducted 10 independent reviews related to instructor-initiated withdrawals in order to assess the accuracy of the student withdrawal dates within the SIS after implementation of the new process. The results of such reviews identified numerous and various exceptions such as unmatched withdrawal dates between the Canvas Learning Management System (Canvas) and SIS, missing participation dates in Canvas for students re-added to course history, and instances where the last date of student participation could not be determined within the Canvas.
Cause and Effect:
A. Incorrect Calculation of Return of Title IV Funds
Los Angeles Harbor College
The Financial Aid Senior Accounting Technician who processed the Fall 2023 return to Title IV (R2T4) calculations had an oversight on clicking the save button to update the SIS R2T4 worksheet for these 2 students. The calculations and review of the R2T4 batch were accurate, but the worksheets E, F, and G award updates were not saved in the SIS, which caused the calculations to be slightly off.
B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student
Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP)
Despite the best efforts of the District office to implement the active enrollment roster as well as messaging to faculty with the requirement to complete the active enrollment roster and post the students last date of attendance, internal review demonstrated that additional actions must be taken to improve compliance. The SIS is used to maintain student records and for administering aid. Incorrect information in the SIS can lead
to an incorrect return of Title IV funds calculation. Without a process to determine accuracy of student withdrawal dates, there is a risk of incorrect return of Title IV calculations.
Questioned Costs:
A. Incorrect Calculation of Return of Title IV Funds - see schedule of findings and questioned costs.
B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student
Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) - Not applicable.