Finding 404731 (2023-010)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-06-29
Audit: 311103
Organization: College Unbound (RI)

AI Summary

  • Core Issue: The College failed to provide exit counseling for 5 out of 40 sampled students who ceased at least half-time study, violating federal requirements.
  • Impacted Requirements: Compliance with 34 CFR 685.304(b) regarding mandatory exit counseling for Direct Loan borrowers upon graduation or withdrawal.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all eligible students receive exit counseling within the required timeframe.

Finding Text

Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 685.304(b): (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 study-abroad 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exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling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 5 students, out of a sample of 40, did not have evidence that exit counseling was performed. Our sample was not, and was not intended to be, statistically valid. 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 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control 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

Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Corrective Action Plan: The college has implemented controls in place to ensure that exit counseling is conducted with Direct Loan borrowers following changes in enrollment as required. As of FY24, this finding has been corrected. Exit interviews have been sent for FY24 and we will continue to work with our borrowers to understand their loan repayment options. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO

Categories

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 404720 2023-002
    Significant Deficiency Repeat
  • 404721 2023-003
    Significant Deficiency
  • 404722 2023-004
    Material Weakness Repeat
  • 404723 2023-004
    Material Weakness Repeat
  • 404724 2023-005
    Significant Deficiency
  • 404725 2023-006
    Material Weakness Repeat
  • 404726 2023-006
    Material Weakness Repeat
  • 404727 2023-007
    Significant Deficiency Repeat
  • 404728 2023-007
    Significant Deficiency Repeat
  • 404729 2023-008
    Material Weakness Repeat
  • 404730 2023-009
    Significant Deficiency
  • 404732 2023-011
    Significant Deficiency Repeat
  • 404733 2023-011
    Significant Deficiency Repeat
  • 404734 2023-012
    Significant Deficiency
  • 981162 2023-002
    Significant Deficiency Repeat
  • 981163 2023-003
    Significant Deficiency
  • 981164 2023-004
    Material Weakness Repeat
  • 981165 2023-004
    Material Weakness Repeat
  • 981166 2023-005
    Significant Deficiency
  • 981167 2023-006
    Material Weakness Repeat
  • 981168 2023-006
    Material Weakness Repeat
  • 981169 2023-007
    Significant Deficiency Repeat
  • 981170 2023-007
    Significant Deficiency Repeat
  • 981171 2023-008
    Material Weakness Repeat
  • 981172 2023-009
    Significant Deficiency
  • 981173 2023-010
    Significant Deficiency
  • 981174 2023-011
    Significant Deficiency Repeat
  • 981175 2023-011
    Significant Deficiency Repeat
  • 981176 2023-012
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.23M
84.063 Federal Pell Grant Program $1.04M
21.027 Coronavirus State and Local Fiscal Recovery Funds $809,807
84.116 Fund for the Improvement of Postsecondary Education $543,306
84.425 Education Stabilization Fund $324,547
84.007 Federal Supplemental Educational Opportunity Grants $12,170
84.033 Federal Work-Study Program $9,982