Finding Text
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 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: A transfer student was not added to the Transfer Monitoring List.
Cause: Administrative oversight.
Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process.
Questioned Costs: None.
Context: For 1 of 8 students sampled, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-003.
Recommendation: We recommend the University enhance its procedures 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 error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy.