Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - P268K221640, P063P121640, and P007A212038 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Before an institution disburses Title IV, Higher Education Act (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Except in the case of a post-withdrawal disbursement made in accordance with Sec. 668.22(a)(5), if an institution credits a student's account at the institution with Direct Loans, the institution must notify the student or parent of: i.The anticipated date and amount of the disbursement ii.The student's or parent's right to cancel all or a portion ofthat loan or loan disbursement and have the loan proceeds returned to the secretary iii.The procedures and the time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Unless otherwise directed by the granting agency, an institution must maintain records related to its administration of a student financial assistance program for three years after the end of the award year in which the FISAP is submitted (34 CFR 668.24). Condition - The University could not provide records to substantiate that the relevant criteria were complied with by the University in all cases. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 13 students tested for R2T4, there were 6 students who were unofficial withdrawals in which the University could not provide support to substantiate the last date of academically related activity that was used as the withdrawal date for Title IV calculation purposes. Of the 25 students tested for eligibility, there were 2 students in which the University could not provide support that a disbursement notification was sent to the student/parent. Cause and Effect - Processes and controls are not designed and implemented to ensure that proper record retention is occurring necessary to substantiate compliance with relevant requirements. Recommendation - The University should implement additional controls to ensure all appropriate support is retained to backup the inputs of Title IV calculations. The University should implement controls to ensure that appropriate support is retained to support that disbursement notifications were sent to students/parents. Views of Responsible Officials and Planned Corrective Actions - The University concurs with the finding. Madonna will train faculty to preserve and provide documentation related to reported last dates of attendance. This will be stored in the University's enterprise document management system.