Finding Text
Federal Program Information: Federal Direct Student Loans (ALN #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Transfer Monitoring - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Students Loan Data System (the ?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. However, a school does not have to wait if it receives an alert during the 7-day period or if it obtains the student's financial aid history by accessing the NSLDS Financial Aid Professional website. When a school receives an alert from NSLDS, before making a disbursement of Title IV aid, it must determine if the change to the student's financial aid history affects the student's eligibility (34 CFR section 668.19). Condition: Instances were identified where the College disbursed Title IV aid prior to informing NSLDS about transfer students. Cause: Lack of administrative oversight and insufficient internal controls with respect to transfer monitoring requirements. Effect: The College was not in compliance with the transfer monitoring requirements. Questioned Costs: None. Context: For 2 of 2 students selected for testing, the College did not properly inform NSLDS of transfer students prior to disbursing Title IV aid. Identification as a Repeat Finding: This is a repeat finding of prior year finding 2021-005. Recommendation: We recommend the College enhance its procedures and internal controls to ensure compliance with transfer monitoring requirements. Views of Responsible Officials and Planned Corrective Actions: The College acknowledges the requirement that schools obtain financial aid history information for their transfer students. 2 student files were identified as a compliance finding out of the 2 students sampled. This is a repeat finding from the prior year (June 30, 2021) but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures where it will work closely with the Office of Admission and update NSLDS manually to ?inform? it of the transfer students applying to PC mid-year. This is a relatively small group of students. For those students included on a school?s ?Inform? list, NSLDS ?Monitors? changes to the student?s financial aid history that have occurred since the latest ISIR for the student was generated and sent to the school. NSLDS will continue to monitor changes to the student?s financial aid history, and alert the school of any subsequent relevant changes. A staff member in the Office of Financial Aid will be assigned to review the Transfer Monitoring files.