Finding Text
Section III - Federal Awards Findings and Questioned Costs
Finding 2024-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency
Name of Federal Agency: U.S. Department of Education
Federal Program Name: Federal Direct Student Loans
Assistance Listing Number: 84.268
Federal Award Identification Number and Year: P268K243382 2024
Name of Pass-through Entity: N/A
Criteria
According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling
is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the
student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304
(b)(7)).
Condition
We noted 1 instance where the Institute failed to document exit counseling which should have been
conducted with a participating student during the award year.
Cause
There was an administrative oversight that caused the above mentioned condition.
Effect or Potential Effect
The Institute was not in compliance with federal regulations regarding special tests and provisions for
the year ended September 30, 2024.
Questioned Costs
None
Context
A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year
were included in the haphazardly selected sample of 40 participating students. Our testing noted that 1
of the students with Federal Direct Loan Program proceeds credited to their account did not have the
required exit counseling documented.
Identification as a repeat finding
This finding is not a repeat finding. Recommendation
We recommend the Institute continue its efforts to ensure all required exit counseling procedures are
conducted and documented in compliance with U.S. Department of Education regulations.
Views of Responsible Officials
The failure to document the exit conference of one student borrower in the Federal Direct Loans
Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute
reviewed and revised its current procedures to ensure that all exit conferences are documented. Under
the revised procedures, an employee independent from the exit conference process is to review that
any student that has not enrolled in a new semester or that is enrolled at less than half time status has
received proper exit conferencing and that the exit conferencing has been properly documented.