Finding 1186697 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-26

AI Summary

  • Core Issue: The College failed to provide exit counseling for 6 out of 40 sampled students who graduated or withdrew, violating federal requirements.
  • Impacted Requirements: Exit counseling must be conducted within 30 days when students cease at least half-time study, withdraw, or graduate.
  • Recommended Follow-Up: The College should improve procedures to ensure all eligible students receive exit counseling as required.

Finding Text

Criteria According to 34 CFR 685.304(b): Counseling Borrowers - Exit Counseling (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a studyabroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition The Federal Government requires that when the student ceases at least half-time study, withdraws from all classes or graduates, the college must provide exit counseling to students within 30 days. During our testing, we noted 6 students, out of a sample of 40, did not have evidence that exit counseling was performed. Cause The College did not have adequate controls in place to ensure that exit counseling was conducted with Direct Loans borrowers following changes in enrollment which require administration of exit counseling for Direct Loans. Effect The College did not meet federal requirements and students did not complete exit counseling following graduation, cease of enrollment. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 6 students, or 15% of our sample, had students that graduated or disenrolled and did not complete exit counseling. Identification as a Repeat Finding, if applicable See finding 2024-001 included in the summary schedule of prior year findings. Recommendation The College should strengthen their procedures to ensure exit counseling is completed for a student when student ceases enrollment at least half-time, withdraws, or graduates from the College. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Corrective Action Plan: Because several issues related to compliance requirements surrounding enrollment status changes were identified in this process, we have developed a unified reporting tracking system to ensure the Registrar, the Office of Student Financial Assistance, and the Office of Fiscal Affairs all have visibility into the requirements when students leave the institution. This report will show all students identified by the registrar as having withdrawn, the date of determination, and the deadlines for NSLDS reporting, Exit Counseling, and R2T4 actions if necessary. This report will be visible to all three offices, and will automate the identification of the due dates for exit counseling and follow up communication, ensuring each action is taken within the required timeframe. It will improve oversight of this process as the status of each student’s participation or lack thereof in the exit counseling process, as well as the status of required additional communication to the student will be visible to several staff members across several functions. Further, the Financial Aid office will identify an additional staff member to grant access to this report to assist the Director in ensuring exit counseling is conducted within the required timeframe moving forward. Timeline for Implementation of Corrective Action Plan: This report is currently under construction and will be fully implemented by Apr 1, 2026.

Categories

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Other Findings in this Audit

  • 1186698 2025-002
    Material Weakness Repeat
  • 1186699 2025-003
    Material Weakness Repeat
  • 1186700 2025-003
    Material Weakness Repeat
  • 1186701 2025-004
    Material Weakness Repeat
  • 1186702 2025-005
    Material Weakness Repeat
  • 1186703 2025-005
    Material Weakness Repeat
  • 1186704 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $11.34M
84.063 FEDERAL PELL GRANT PROGRAM $3.77M
84.033 FEDERAL WORK-STUDY PROGRAM $88,187
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $87,146
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $16,594
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $0