Finding Text
2023-006 Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct
Loan Program, ALN #84.268)
Criteria: In accordance with 34 CFR 682.604(a)(1), a school must ensure that exit counseling is
conducted with each borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is provided or conducted
within 30 days after learning that the student borrower has withdrawn from school or dropped below
half-time enrollment.
Statement of Condition: During the 2023 audit, it was noted that certain students who had dropped
below half-time enrollment or who had left the University were not provided with exit counseling in
relation to outstanding federal direct loan balances.
Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature.
Perspective Information: The 2023 audit included a detailed testing of 40 student files, of which this
significant deficiency applies to 9, indicating an error rate of 22.5%.
Cause and Effect: Due to an internal information technology error, the University was not able to
maintain documentation showing that exit counseling information was sent to the affected students.
Recommendation: The University should verify that appropriate communication is made to students
leaving the University or lowering enrollment to less than half time, who also have outstanding federal
direct loans balances, to provide each with the exit counseling resource.
View of Responsible Officials: Once IT was made aware of the issues, we implemented changes to the
process. The action code was discontinued, and our database administrator developed a custom
database table used only for tracking Financial Aid communications. This custom table tracks the
student’s organizational ID number, email address, communication code (EXIT for exit counseling
emails), date/time the email was processed, and the status returned by the process used to send
emails. Please note that this status only checks whether the process succeeded, it does not check
whether the email was successfully sent. The Financial Aid Department is still copied in all emails sent
at their main email address (currently FinancialAidTN@Johnsonu.edu). The Financial Aid Department
has the responsibility to alert the IT Department if they are not receiving emails as expected. Once
the IT Department has been alerted of an issue, the IT Department can start working to resolve the
issue.
For long-term reliability of communications, Johnson University has purchased and is implementing a
new Financial Aid software platform. This will give us an opportunity to work towards reliable
communications, not just reliable logging of process failures or successes.