Finding Text
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will “monitor” those students on the school’s “inform” list and “alert” the school of any relevant financial aid history changes. A school must wait 7 days after it “informs” NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).
Condition: Certain students were added to the Transfer Monitoring List post factum.
Cause: Administrative oversight and insufficient internal controls.
Effect or Potential Effect: The College did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 3 of 6 students tested, the College disbursed Title IV funds prior to adding the student to the NSLDS alert list.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend that the College enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid.
Views of Responsible Officials: The College agrees with this finding. The Financial Aid Office has updated the rules in the SIS system to not allow payment until the NSLDS reporting has been processed. The current financial aid procedures have been updated and the rules are currently in place.