Moore College of Art and DesignHigher Education

Finding 2025-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable ALN Number: 84.063, 84.268 Federal Award Number: P063P242121, PK268K252121 Federal Award Year: June 30, 2025 Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for seven of eleven students tested as part of our sample for Return of Title IV (R2T4) testing were not calculated correctly and resulted in the College refunding incorrect amounts to the Title IV Program. The sample was not a statistically valid sample. Questioned Costs: For federal award P268K252121, Federal Direct Student Loans, the College returned $455 more than required for two students tested. For federal award P063P242121, Federal Pell Grant Program, the College returned $338 more than required for five students. Cause: The College did not properly calculate the number of days in a term (excluding breaks of five days or more) which resulted in the incorrect unearned aid percentage to be used in the refund calculation. Effect: The amounts refunded to the U.S. Department of Education were incorrect. The amount returned was more than what should have been returned. Recommendation: The College should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work with the College's Director of Financial Aid, Controller and Registrar to review all rules regarding return to title IV calculations so a guide can be created to lessen the chance of incorrect calculations going forward.

Finding 2023-001 - Return of Title IV Funds Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable ALN Number: 84.063, 84.268 Federal Award Number: P063P222121, PK268K232121 Federal Award Year: June 30, 2023 Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for one of twelve students tested as part of our sample were not returned timely to the Title IV Program. For the one student not returned within the 45 days, the total award to be returned was $5,255. The sample was not a statistically valid sample. Questioned Costs: None. Cause: The College’s procedures for the return of Title IV funds were not followed consistently throughout the period. Effect: The amounts refunded to the Department of Education were refunded late. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more thorough review process to ensure funds required to be returned within 45 days comply with the Title IV regulations. Views of Responsible Officials and Planned Corrective Actions: On a weekly basis, the Registrar will download the Registration Status Report from the student information system and review the report for accuracy. A copy will be provided to the Director of Financial Aid and the Accounts Receivable Coordinator to ensure all withdrawn students have been communicated in a timely fashion and all R2T4s are processed timely.

Finding 2023-002 - Student Status Changes Federal Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable ALN Number: 84.007, 84.063, 84.268 Federal Award Number: P007A223647, PP063P222121, PK268K232121 Federal Award Year: June 30, 2023 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for two (2) of eleven (11) students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. The sample was not a statistically valid sample. Questioned Costs: None. Cause: The College’s procedures for reporting student status changes were not designed appropriately to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the College. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: The College should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe. Views of Responsible Officials and Planned Corrective Actions: On a monthly basis, the Registrar will download the Registration Status report from the student information system and review the report for accuracy to ensure all enrollment changes are captured. Once the review is complete, the information will be uploaded to the National Student Clearinghouse.

Finding 2022-001 - Verification Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.268 Federal Award Number: P268K222121 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional Federal Perkins Loan or FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition/Context: For one student tested out of total population of one student for V4/V5 verification who received subsidized and unsubsidized direct loans, there was no documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), was completed prior to Federal funds being disbursed to students. The sample was not a statistically valid sample. Questioned Costs: The total direct loans disbursed to the student during fiscal year 2022 was $10,392. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendation: We recommend that the School put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Actions: The U.S. Department of Education waived the requirement for verification for academic year 2021/2022 for V1, V2 and V3 students, however institutions were required to complete verification for V4 and V5 students. All of the College's students fell under V1, V2 and V3 except for one student. The College has created a selection set in its financial aid software to identify these students so they will be selected for verification. Finding 2022-001 - Verification Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.268 Federal Award Number: P268K222121 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional Federal Perkins Loan or FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition/Context: For one student tested out of total population of one student for V4/V5 verification who received subsidized and unsubsidized direct loans, there was no documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), was completed prior to Federal funds being disbursed to students. The sample was not a statistically valid sample. Questioned Costs: The total direct loans disbursed to the student during fiscal year 2022 was $10,392. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendation: We recommend that the School put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Actions: The U.S. Department of Education waived the requirement for verification for academic year 2021/2022 for V1, V2 and V3 students, however institutions were required to complete verification for V4 and V5 students. All of the College's students fell under V1, V2 and V3 except for one student. The College has created a selection set in its financial aid software to identify these students so they will be selected for verification.

Finding 2022-002 - Reporting Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.033 Federal Award Number: P033A203647 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 674.19(d)(2), 34 CFR 675.19(b)(3) and 34 CFR 676.19(b)(3)) require institutions to submit a Fiscal Operations Report and Application to Participate (FISAP) annually and to ensure that the information reported on the FISAP is accurate. Condition/Context: During our testing of the June 30, 2021 FISAP, one error was noted. The sample was not a statistically valid sample. Questioned Costs: None noted. Cause: Included in the total Federal Work Study (FWS) was $19,845 from the Pennsylvania Higher Education Assistance Agency (PHEAA) FWS On Program which should not have been included in this total amount since it was not federal funds. Effect: Certain balances related to the College's federal programs are not being accurately represented to the Department of Education. Recommendation: The College should review and revise its procedures for the FISAP preparation and review to ensure accurate information is reported on the FISAP in a timely manner. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, it is clear that additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.

Finding 2022-003 - Return of Title IV Funds Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.063, 84.268 Federal Award Number: PK268K222121, P063P212121 Federal Award Year: June 30, 2022 Repeat Finding: 2021-001 Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for two of five students tested as part of our sample were not calculated correctly and resulted in the College refunding incorrect amounts to the Title IV Program. In addition, the College identified five other students for which the R2T4 calculations were incorrect. The sample was not a statistically valid sample. Questioned Costs: For federal award P268K222121, Direct Loans, the College returned $14 more than required for one student tested. For federal award P063P212121, Pell, the college returned $67 more than required for one student. For the five additional students that the College identified as having incorrect return calculations, $457 was returned in excess for award P063P212121 and $84 was returned in excess for award P268K222121. Cause: The College did not properly calculate the number of days in a term (excluding breaks of five days or more) which resulted in the incorrect unearned aid percentage to be used in the refund calculation. Effect: The amounts refunded to the Department of Education were incorrect. To be specific, the amount returned was more than should have been returned. Recommendation: The College should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations in order to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.

Finding 2021-001: Return of Title IV Funds Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.007, 84.033, 84.063, 84.268 Federal Award Number: P033A203647, PK268K212121, P063P202121, P007A203647 Federal Award Year: June 30, 2021 Criteria: 34 CFR 668.22 requires that 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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: During testing we noted seven (7) instances where the amount of the Title IV refund was calculated incorrectly for the student of nineteen (19) students tested. There were a total of 19 students who withdrew during fiscal year 2021 that received Title IV aid. Questioned Costs: Questioned costs of $884 were identified during our testing. The University returned $188 more Pell grant funds than necessary and $696 more Direct Loan funds than necessary. Cause: The end of the semester dates were entered incorrectly in the calculation for all seven instances and the number of days completed were overridden in one instance. Effect: The amounts refunded to the Department of Education were incorrect. To be specific, the amount returned was more than should have been returned. Recommendation: The University should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations in order to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: The Director of Financial Aid will ask the Registrar to review academic calendar dates used for R2T4 calculations to ensure they are accurate.

Finding 2021-002: HEERF Funds Reporting and Public Posting Federal Program: COVID-19 - Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.425E and 84.425F Federal Award Number: P425E20410, P425F203429 Federal Award Year: June 30, 2021 Criteria: Section 18004(e) of the Coronavirus Aid, Relief and Economic Security Act (CARES Act), directed institutions receiving funds under Section 18004 of the Act, to submit a report to the Secretary describing the use of funds distributed from the HEERF. Beginning on May 6, 2020, the Department of Education (ED) required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award. Additionally the CARES, CRRSAA and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution's website. The forms must be posted on the institution's primary website on the same page the reports for the emergency financial aid grants to students (Student Aid Portion) are posted. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2) and (a)(3) funds and checks the "final report" box. IHEs must post this quarterly report form no later than ten days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. Condition/Context: The College did not file the March 31, 2021 quarterly budget and expenditure report for the institutional portion by the due date of July 10, 2021. The March 31, 2021 report was filed on October 8, 2021. In addition, the information required to be posted under the CARES Act for the student portion to the College's website were not posted within the required time frames. The December 31, 2020 quarterly information was posted on January 12, 2021 and the June 30, 2021 quarterly information was posted on October 8, 2021. Cause: The College did not monitor deadlines for HEERF reporting requirements. Effect: The College did not comply with the ten day posting requirement related to the HEERF Student Aid Portion at the end of each quarter. The College also did not comply with the ten day after the end of each calendar quarter reporting requirement for the Institutional Portion. Recommendation: The College should assign an individual to track reporting requirements of awards to ensure the College is in compliance. Views of Responsible Officials and Planned Corrective Actions: The College has tasked the Director of Financial Aid with the responsibility to track reporting requirements and ensure the College is in compliance.

Finding 2020-001: Overaward of Federal Supplemental Education Opportunity Grant (SEOG) Funds Federal Program ? Federal Supplemental Education Opportunity Grants Federal Agency - U.S. Department of Education Pass-Through Entity - Not applicable CFDA Number - 84.007 Federal Award Number ? P007A193647 Federal Award Year - June 30, 2020 Criteria: FSEOG regulations (34 CFR 676.10 and 676.20) states that the institution decides the amount of the student grant awards. Institutions can award a maximum of $4,000 but not award less than $100, for an academic year. The maximum amount may be increased by $400 to $4,400 for students participating in a study abroad program that is approved for credit by the student's home institution. Condition/Context: During testing we noted four instances where the College awarded FSEOG funds above $4,000 to students that were not participating in study abroad programs approved for credit. The sample was not a statistically valid sample. Questioned Costs: The four students were awarded total FSEOG funds of $17,600 which included $1,600 of funds the students were not eligible for. Cause: The information technology system used by the College allowed for a maximum award of $4,400 regardless of students' participation in a study abroad program approved for credit. The College lacks a review process to identify overawards of FSEOG funds. Effect: Four students received FSEOG funds in excess of the maximum award and were not participating in student abroad programs approved for credit. Recommendation: The College should revise its procedures for awarding Student Financial Aid, specifically FSEOG, to ensure that aid is awarded correctly, within limits, and that a process is in place to prevent overawards of FSEOG funds. Views of Responsible Officials and Planned Corrective Actions: The College has implemented a change to the awarding software that will not allow for FSEOG awards in excess of $4,000 without an administrative over-ride. The rules regarding maximum FSEOG have been brought to the attention of staff and added to training materials provided to all new employees. The over-awarded were returned June 2021.

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