Finding Text
Finding 2023-002– Short-Term Program Completion and Placement Rates
Repeat Finding: Yes
Federal Program Title – U.S. Department of Education
Student Financial Assistance Cluster
Federal Direct Student Loans: 84.268
Federal Award Year 2022-2023
Condition
The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program.
Criteria
For the Direct Loan Program, short-term eligible programs at a postsecondary vocational institution must be between 300 - 599 clock hours. They must have been provided for at least one year and must have a substantiated completion and placement rate of at least 70 percent for the most recently completed award year. 34 CFR Section 668.8(f) and (g) requires the college to have documentation supporting its placement rates for each student showing that the student obtained gainful employment in the recognized occupation for which he or she was trained or in a related comparable recognized occupation.
2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure compliance with completion and placement rate calculations for short-term programs.
Questioned Costs
There were no questioned costs with respect to this finding.
Cause
The financial aid office did not follow-up on the gainful employment of students.
Prevalence
Frequent. Two out of two students who completed the program did not have sufficient support for the placement rate calculation. Five out of seven students tested did not successfully complete the programs resulting in a completion rate below 70%.
Effect
Failure to calculate the placement data for each student or achievement of the required completion rate is noncompliance with Federal regulation and could result in loss of future funding
Recommendation
We recommend City Colleges enhance their policies and procedures to ensure that calculation of placement rates is being maintained and that completion rates are being monitored for compliance.
Views of responsible officials
We agree with this finding. See corrective action plan.