Finding Text
Program Information: Student Financial Assistance Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. 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 Student Loans Data System (“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 (34 CFR section 668.19).
Condition: The University did not add the transfer students to the NSLDS ‘alert’ list and was unable to provide documentation supporting those the students’ financial aid history was reviewed prior to disbursing Title IV aid.
Cause: Lack of internal controls and administrative oversight.
Effect or Potential Effect: The University is not in compliance with the required federal guidelines over transfer monitoring.
Questioned Costs: None.
Context: The University was unable to provide an accurate listing of students who transferred into the University during the year and did not appropriately add the students to the NSLDS ‘alert’ list as required.
Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2020-013 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that all transfer students are appropriately tracked/monitored as required by federal guidelines.
Views of Responsible Officials and Planned Corrective Actions: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid while informing other institutions of those changes through the National Student Loan Data System (NSLDS). This issue has been resolved with the implementation of Colleague. The Financial Aid Director can now perform transfer monitoring in Colleague to track transfer students and any changes to their financial aid while informing other institutions of those changes. Colleague sends information files to the National Student Loan Data System (NSLDS), which notifies NSLDS of our transfer students and serves as a request to put SAU's transfer students on the NSLDS maintained Transfer Monitoring list. The inform file is also a request for a Financial Aid History file for each student listed. With Colleague, we can determine which students to monitor, send the information to NSLDS, transfer the files, and view students' NSLDS information as necessary. The Financial Aid Director runs transfer monitoring at the beginning of the semester for everyone enrolled and then runs TMXP, which creates a file to monitor those who are newly awarded, Students are run through the process in December for new transfer student can be monitored. With Colleague, the Financial Aid Director/Staff can easily adhere to the "Inform, Monitor, Alert" process since this system can efficiently and effectively run this process. Prior to awarding a transfer for spring the Financial Aid Staff as alternative option review NSLDS and manually add a student to the transfer monitoring file.