Finding 29575 (2022-002)

-
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The University failed to send exit counseling communications to two students within the required 30-day period after determining their graduation status.
  • Impacted Requirements: Compliance with federal regulations mandates timely exit counseling for student loan borrowers before they cease half-time study.
  • Recommended Follow-Up: Implement a plan to ensure timely exit counseling notifications are sent to all relevant students moving forward.

Finding Text

COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria 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. 34 C.F.R. ? 685.304 (b)(1). 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exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling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. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan

Corrective Action Plan

The Institution?s inability to send exit counseling notifications to the 2 students in the sample list had to do with the ransomware attacks to our information systems on 10/2/2021. Our information system was shut down during the cyber incident resulting in limited access to student data. WAU acknowledges the importance of conducting exit counseling of each Direct Subsidized loan or Direct Unsubsidized loan borrower and graduate or professional student Direct PLUS Loan borrower who graduates, withdraws or ceases to be enrolled at least Half Time. WAU is committed to providing loan counseling including Exit Counseling to students in accordance with the Federal regulations to prevent student loan defaults and avoid increased expenses for the Federal Department of Education. The Financial Aid office completed a file review for students who graduated in the 2021-2022 award year to identify student not sent exit counseling notification and send exit counseling notifications to them. The financial aid office has created an exit counseling process and procedure to use as an internal control measure to help ensure that exit counseling is conducted with each Direct loan or Direct Unsubsidized loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases to be enrolled least half-time at WAU. The Direct Loans Officer will coordinate with the Student Accounts office and the Registrar to ensure that graduating students are sent exit counseling notification not earlier than a month before graduation. The updated Direct Loan Counseling information and the University?s processes and procedures for conducting exit counseling will be updated in our 2023-2024 Academic Bulletin.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.38M
84.425 Education Stabilization Fund $1.55M
84.063 Federal Pell Grant Program $1.47M
84.038 Federal Perkins $761,575
84.007 Federal Supplemental Educational Opportunity Grants $95,661
84.033 Federal Work-Study Program $87,676
93.364 Nursing Student Loans $50,104