Finding 513949 (2024-001)

MATERIAL WEAKNESS 2024-001 Federal Program Student Financial Assistance Cluster Compliance requirements Reporting and Special Tests and Provisions – Return to Title IV and Enrollment Reporting Criteria or specific requirement When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. For institution’s who take attendance, except in unusual instances, the date of the institution’s determination the student withdrew should be no later than 14 days after the student’s last date of attendance, as determined by the institution from its attendance taking records. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as soon as possible, but no later than 45 days after the date the institution determined the student withdrew. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a postwithdrawal disbursement, which must be disbursed to the student’s account no later than 45 days after the date of the institution’s determination that the student withdrew. Additionally, upon determining that a student has had a change in their enrollment level, such as with a withdrawal, institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster files or on the Enrollment Maintenance page of the NSLDS Professional Access website. At minimum, institutions are required to certify enrollments every 60 days, and when a Direct Loan was made to or on behalf of a student who was enrolled, and the student ceased to be enrolled on at least a half-time basis, the institution should report the change in its next updated Enrollment Reporting Roster file. Condition The College's official policy is to be an attendance taking institution. However, the date of the institution’s determinations for withdrawals does not fall within the required 14 day period, and it instead follows that of institutions that are not attendance taking. Additionally, during testing, it was identified that the College's quality control processes for Return to Title IV calculations were not completed within a timely manner, and that process determined that calculations needed to be adjusted for some of the students. Those corrections were not made within the required 45 day periods, and, as a result of the late corrections, the NSLDS enrollment reporting also had to be updated outside of its typical window. Context Of the 31 students tested for Return to Title IV procedures, 10 went through the College’s quality control process during the fall of 2024. Cause The initial Return to Title IV calculations were not all correct as a result of new staff members being trained to take on the responsibility. However, due to a lack of capacity caused by the additional workload coming from the FAFSA overhaul that was implemented during the period, the more experienced staff members could not complete the quality control corrections for some time. Effect Date of determinations of withdrawals are not being completed within the required timeframe, final postwithdrawal disbursement or return of aid adjustments were not made within the required timeframe, and NSLDS enrollment reporting was not updated timely. Recommendation We recommend that the College review and update its policies to ensure that all compliance requirements are met within the required timeframes associated with those policies, as well as recommend that the College review its controls to ensure that accurate Return to Title IV calculations are completed in a timely fashion. Views of responsible officials See Corrective Action Plan.