Finding 943174 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-02-09

AI Summary

  • Core Issue: Incorrect calculations of Return of Title IV Funds and delays in notifying students about grant overpayments, alongside a lack of formal processes for determining student withdrawal dates.
  • Impacted Requirements: Compliance with federal regulations regarding Title IV funds, specifically the accurate determination of withdrawal dates and timely notifications as outlined in 34 CFR 668.22.
  • Recommended Follow-Up: Establish a formal process for tracking student attendance and withdrawal dates, and ensure timely communication with students regarding any financial adjustments to their aid.

Finding Text

Finding FA 2023-002: Special Tests and Provision: Return of Title IV Funds: Incorrect Calculation of Return of Title IV Funds, Untimely Notification of Grant Overpayment to Students and Secretary, Distance Education Courses – Lack of Formal Process to Determine Accuracy of Student Withdrawal Date (Repeat Finding) Federal Program Information Federal Catalog Number: ALN 84.007, 84.033, 84.038, 84.048, 84.063 and 84.268 Federal Program Name: Student Financial Assistance Cluster; Federal Pell Grant Program Federal Direct Student Loans Federal Agency: U.S. Department of Education Passed Through Entity: N/A Federal Award Number: P007A210456, P063P215260, P268K225260 P007A210676, P063P215262, P268K225262, 21-C01-740 Federal Award Year: July 1, 2022, to June 30, 2023 Campuses: Los Angeles City College (Repeat Finding) East Los Angeles College (Repeat Finding) Los Angeles Harbor College (Repeat Finding) Los Angeles Mission College (Repeat Finding) Los Angeles Pierce College (Repeat Finding) Los Angeles Southwest College (Repeat Finding) Los Angeles Trade Technical College (Repeat Finding) Los Angeles Valley College (Repeat Finding) West Los Angeles College (Repeat Finding) Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds Criteria or Specific Requirement: Per 34 Code of Federal Regulations 668.22 (a)(1) through (a)(5): When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement. Per the Uniform Guidance Compliance Supplement: Withdrawal Date: If an institution is required to take attendance, the withdrawal date is the last date of academic attendance, as determined by the institution from its attendance records. An institution is required to take attendance if: a. The institution is required to take attendance for some or all of its students by an entity outside of the institution (such as the institution’s accrediting agency or state agency); b. The institution itself has a requirement that its instructors take attendance; or c. The institution or an outside entity has a requirement that can only be met by taking attendance or a comparable process, including, but not limited to, requiring that students in a program demonstrate attendance in the classes of that program or a portion of that program (34 CFR 668.22(b)(3)). Note: As provided in the Department’s Program Integrity Q&As for Return of Title IV Funds, the monitoring of whether online students log into classes does not by itself result in an institution being an institution that is required to take attendance for Title IV, HEA program purposes because monitoring logins alone is not monitoring academic engagement (as defined under 34 CFR 600.2). However, an institution that collects and maintains information about students’ online activities for the purpose of tracking academic engagement is considered to be an institution that is required to take attendance for programs involving such tracking if that tracking: 1. Involves monitoring student attendance in a synchronous class, lecture, recitation, or field or laboratory activity, physically or online via a distance education platform, where there is an opportunity for interaction between the instructor and students; or 2. Is used to administratively withdraw students or to enforce an institutional attendance policy. If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, 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 (l)). Title IV funds may be expended only towards the education of the students who can be proven to have been in attendance at the institution. In a distance education context, documenting that a student has logged into an online distance education platform or system is not sufficient, by itself, to demonstrate attendance by the student. To avoid returning all funds for a student that did not begin attendance, an institution must be able to document “attendance at any class.” To qualify as a last date of attendance for Return of Title IV purposes, an institution must demonstrate that a student participated in class or was otherwise engaged in an academically related activity, such as by contributing to an online discussion or initiating contact with a faculty member to ask a course-related question. Timing of Return of Title IV Funds Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Identified Condition: See schedule of findings and questioned costs Description A. Incorrect Calculation of Return to Title IV Funds East Los Angeles College We noted 1 of 15 students selected for return of Title IV funds test work from the population of students who had withdrawn, dropped out, or never began attendance that had an incorrect calculation of percentage of completion for Spring 2023 based on the student’s actual number of days completed during the enrollment period. The student was enrolled in a session module course, which is a program that does not span the entire length of the payment period or period of enrollment. For this type of course, the student’s “actively enrolled days” should have been used in the return of Title IV funds calculation. This error resulted in an overstatement of the institutional return by $13 and an overstatement of the student’s return by $21. The effect of the overstatement of the student’s return did not result in a questioned cost due to grant protection. Los Angeles Southwest College We noted 6 of 20 students selected for return of Title IV funds test work from the population of students who had withdrawn, dropped out or never began attendance for Fall 2022 that had had an incorrect calculation of the percentage of completion based on the student’s number of days completed during the enrollment period. For 3 students, these errors resulted in: • 1 student with an understatement of institutional return of $37 and an understatement of student return of $287. • 1 student with an understatement of institutional return of $11 and an understatement of student return of $197. • 1 student with an overstatement of institutional return of $10 and overstatement of student return of $20. The effect of the above overstatement of the student return did not result in questioned costs due to grant protection. For the remaining 3 students, we noted these students were enrolled in a session module course, which is a program that does not span the entire length of the payment period or period of enrollment. For this type of course, the student’s “actively enrolled days” should have been used in the return of Title IV funds calculation These errors resulted in: • 1 student with an overstatement of institutional return of $30. • 1 student with an overstatement of institutional return of $187. • 1 student with an overstatement of institutional return of $21 and an overstatement of student return of $9. The effect of the overstatement of the student return did not result in questioned costs due to grant protection. B. Untimely Notification of Grant Overpayment to the Secretary We noted that 1 out of 15 students selected for compliance test work at East Los Angeles College that owed an overpayment of $187 as a result of the student’s withdrawal was referred to the Secretary of the Department of Education beyond the 30-day timeframe from the date of the institution’s determination that the student withdrew and owed overpayments as a result of the student’s withdrawal. The required notification was submitted to the National Student Loan Data System (NSLDS) 260 days late. C. Distance Education Courses – Lack of Formal Process to Determine Accuracy of Student Withdrawal Date The District has not yet implemented a formal process in place to monitor a student’s active participation in an online class and engagement in academic activities related to a distance education (DE) course in order to determine the reasonableness and accuracy of the student’s withdrawal date in the system. Currently, the withdrawal date used in the calculation of return to Title IV funds is the actual date the student initiates the withdrawal from the course in the system. Cause and Effect: A. Incorrect Calculation of Return to Title IV Funds East Los Angeles College The Financial Aid Technician who processed the Spring 2023 return to Title IV had an oversight on that record during his review process. He had a family emergency during that period and had to leave in the middle of his review process. As a result, he forgot to deduct the spring break period from the total number of days for the enrollment period. This caused the calculation to be slightly off. Los Angeles Southwest College The person who was assigned the role of handling the return to Title IV program received limited training before he assumed the duties of return to Title IV calculations while also having to maintain his full load as a Financial Aid Technician. In addition to the limited training, there were changes as to how the program was administered and modules were calculated. This is an arduous task for a seasoned professional and a very challenging task for a novice at best. As with all newly assigned duties, given more time he would have become an expert in handling this program with minimal to zero errors. B. Untimely Notification of Grant Overpayment to the Secretary Every two weeks a new batch of return to Title IV report is released to be processed. The urgency for each report to be completed within a certain time frame created confusion for the NSLDS reporting due date. The same Financial Aid Technician was in charge of completing each step of the process. East Los Angeles College has the largest return to Title IV population. The demand to meet the deadline process caused an oversight for the NSLDS report. C. Distance Education Courses – Lack of Formal Process to Determine Accuracy of Student Withdrawal Date The calculation of return to Title IV funds is a complex process. The District has invested significant resources to improve the accuracy of the process. The District is centralizing and automating the return to Title IV process to minimize potential errors. However, there are still manual aspects to the process. In particular, distance education courses (DE) require faculty to withdraw students from Canvas, the online content delivery application, and Peoplesoft, the District’s student information system. Peoplesoft is used to maintain student records and for administering aid. Incorrect information entered into either system can lead to an incorrect return to Title IV calculation, resulting in institutional liability and/or disciplinary action taken by the U.S. Department of Education. Questioned Costs: A. Incorrect Calculation of Return to Title IV Funds See schedule of findings and questioned costs The District has a known net understatement of the amount due from the student of $434 and a known net overstatement of the amount due from the District of $213. The Projected total net understatement of amounts due from both the student and District is $4,006 as follows: See schedule of findings and questioned costs. This is computed by dividing the errors found in samples per term (Summer term – net understatement $0 and Fall/Spring terms – net understatement $221 over the total Pell awards disbursed in the sample size per term (Summer term – $5,000 and Fall/Spring terms – $176,293) multiplied by the total Pell awards disbursed for the identified colleges per term (Summer term – $67,595 and Fall/Spring terms – $3,195,662). The computation is made on a per-term basis on a campus level and not on a district-wide level. B. Untimely Notification of Grant Overpayment to the Secretary None. C. Distance Education Courses – Lack of Formal Process to Determine Accuracy of Student Withdrawal Date None. Recommendation: We recommend that the District evaluate and improve its existing process and control procedures related to the return of Title IV funds, including notification and return due date requirements. This will help ensure 1) that the returns of Title IV funds are accurately calculated and 2) compliance with the notification and return due date requirements, in accordance with the Uniform Guidance and the Code of Federal Regulation. We recommend that the District implement additional controls at the course instructor level to effectively monitor student participation and engagement in academic activities related to DE courses in order for the instructor to determine the reasonableness and accuracy of a student’s withdrawal date listed in the system. This will help ensure that the withdrawal date used in the calculation of the return of Title IV funds is accurate. Views of Responsible Officials and Planned Corrective Actions: A. Incorrect Calculation of Return to Title IV Funds East Los Angeles College The corrective action plan that will be put in place is to develop a chart with a predetermined number of days based on the enrollment period. This will avoid the manual counting of the number of days for each student. We also trained an additional staff member to help with the workload. This will ensure that errors will be caught before the completion of the review process. Implementation will begin in Spring 2024. Staff is currently being trained. Personnel Responsible for Implementation: Gavino Herrera Position of Responsible Personnel: Financial Aid Supervisor Expected Date of Implementation: Spring 2024 Los Angeles Southwest College The corrective action that we are implementing to remediate this finding is to move the campus return to Title IV processing to the “R2T4 Unit” at the District Office. Personnel Responsible for Implementation: Muniece R. Bruton Position of Responsible Personnel: Financial Aid Manager Expected Date of Implementation: December 1, 2023 B. Untimely Notification of Grant Overpayment to Students and Secretary East Los Angeles College The Corrective Action plan is being implemented by providing an additional staff member to assist with the return to Title IV process along with helping with the validation to ensure calculation, notification, and reporting to NSLDS will be completed on a timely basis. A reminder is set in the Financial Aid Technician Outlook calendar to help remind them to help meet the deadline of the reporting requirement. Personnel Responsible for Implementation: Gavino Herrera Position of Responsible Personnel: Financial Aid Supervisor Expected Date of Implementation: Fall 2023 C. Distance Education Courses – Lack of Formal Process to Determine Accuracy of Student Withdrawal Date In the fall 2022 term, the District implemented training for all Distance Education (DE) faculty members to reduce the risk of data entry errors. DE faculty receive follow-up notifications at the beginning of every term). In addition, the District attempted to conduct random sampling to ensure the accuracy of the data entry. However, the District did not have the authorization or resources to perform sampling during the audit period. As a result, the corrective action plan (CAP) was only partially implemented during fiscal year 2023. In fall 2023, the District secured the human resources and required authorizations to conduct random sampling of the faculty data entry. The District’s Internal Audit Department (IAD) is performing random sampling of all campuses. As of fall 2023, all corrective actions have been fully implemented. Personnel Responsible for Implementation: Steve Giorgi, Betsy Regalado, Keyna Crenshaw Position of Responsible Personnel: Financial Aid Manager, Associate Vice Chancellor of Educational Programs and Institutional Effectiveness, LACCD Supervising Auditor) Expected Date of Implementation: Fall 2023

Categories

Questioned Costs Student Financial Aid Reporting Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $126.71M
84.268 Federal Direct Student Loans $16.51M
84.048 Career and Technical Education -- Basic Grants to States $5.23M
84.031 Higher Education_institutional Aid $5.07M
84.007 Federal Supplemental Educational Opportunity Grants $4.43M
17.268 H-1b Job Training Grants $4.11M
84.002 Adult Education - Basic Grants to States $3.29M
84.047 Trio_upward Bound $2.54M
84.033 Federal Work-Study Program $2.12M
84.042 Trio_student Support Services $2.02M
47.076 Education and Human Resources $1.53M
93.575 Child Care and Development Block Grant $1.04M
93.558 Temporary Assistance for Needy Families $968,316
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $926,696
84.425 Education Stabilization Fund $917,445
84.044 Trio_talent Search $828,866
84.116 Fund for the Improvement of Postsecondary Education $751,361
93.658 Foster Care – Title IV-E $415,268
10.558 Child and Adult Care Food Program $377,562
84.066 Trio_educational Opportunity Centers $283,461
94.006 Americorps $218,918
93.600 Foster Care – Title IV-E $208,217
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $201,605
84.335 Child Care Access Means Parents in School $189,021
17.258 Wia Adult Program $153,532
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $136,959
17.261 Wia Pilots, Demonstrations, and Research Projects $117,009
17.207 Employment Service/wagner-Peyser Funded Activities $113,700
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $113,538
84.038 Federal Perkins Loan Program $69,348
43.008 Education $42,957
47.050 Geosciences $35,011
84.220 Centers for International Business Education $1,000
17.278 Wia Dislocated Worker Formula Grants $336