Finding 538990 (2024-003)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349691
Organization: Berkshire Community College (MA)

AI Summary

  • Core Issue: The College failed to provide exit counseling for 1 out of 12 sampled students who ceased enrollment, violating federal requirements.
  • Impacted Requirements: Exit counseling must be conducted within 30 days for students who graduate, withdraw, or drop below half-time enrollment.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all eligible students receive exit counseling as required.

Finding Text

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exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling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 1 student, out of a sample of 12, 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. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 12 students selected for testing, 1 student, or 8.3% of our sample, had ceased enrollment from the College, and was not provided exit counseling thereafter. 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

Corrective Action Plan:. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Additional reports at the end of each semester have been created to assist with identifying students who fail to complete at least half-time attendance. Policy and procedures have been updated to insure proper Exit Counseling notifications. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person: Karrie M. Trautman

Categories

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

Other Findings in this Audit

  • 1115432 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.51M
84.268 Federal Direct Student Loans $1.33M
84.042 Trio_student Support Services $300,161
93.732 Mental and Behavioral Health Education and Training Grants $209,269
84.048 Career and Technical Education -- Basic Grants to States $93,742
84.033 Federal Work-Study Program $83,340
84.007 Federal Supplemental Educational Opportunity Grants $63,455
17.261 Wia Pilots, Demonstrations, and Research Projects $24,285
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $11,812