Finding Text
Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion
Repeat Finding: No
Federal Program Title – U.S. Department of Education
Student Financial Assistance Cluster
Federal Pell Grant Program: 84.063
Federal Direct Student Loans: 84.268
Federal Supplemental Educational Opportunity Grants 84.007
Federal Award Year 2022-2023
Condition
The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement.
Criteria
Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless:
• The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or
• Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program.
The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal 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 that the appropriate clock to credit hour conversion formula is applied to applicable programs.
Questioned Costs
Unknown
Cause
The College failed to identify certain applicable requirements and therefore did not perform this calculation.
Prevalence
Frequent. Five out of five programs selected for testing.
Effect
Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs.
Recommendation
We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College.
Views of responsible officials
We agree with this finding. See corrective action plan.