DICKINSON COLLEGE

Finding – Eligibility – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement A student may not receive a Direct Unsubsidized Loan unless the student has received a Direct Subsidized Loan for the maximum amount for which the student is eligible. (2022 - 2023 Student Financial Aid Handbook, Volume 3, Chapter 7, Page 3-189, 34 CFR 685.200(a)(iii) Condition Found Of 40 students tested, two students were under-awarded subsidized and unsubsidized loans but were over-awarded subsidized loans. This was not a statistically valid sample. Questioned Costs Known questioned costs of $2,573, likely questioned costs of $41,000. Cause Two students’ cost of attendance increased and when the adjustment was made the increased aid was awarded as unsubsidized loans when there was still subsidized aid available. Identification as a Repeat Finding Not a repeat finding. Recommendation Management should implement a process to perform a final review of subsidized loans to ensure that subsidized loans are maximized before unsubsidized loans are awarded. Views of Responsible Officials and Corrective Action See Corrective Action Plan.

Federal agency: U.S. Department of Education Program name (CFDA #): Student Financial Aid Cluster: Direct Student Loans (CFDA No. 84.268) Federal award year: July 1, 2018 to June 30, 2019 Federal award number: P268K192093 Compliance requirement: Special Tests and Provisions: Enrollment Reporting Criteria. As described in 34 CFR Section 685.309 for Direct Loans, a student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to loan holders by the Department of Education. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted to the National Student Loan Data System (NSLDS) within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Additionally, management is responsible for establishing and maintaining internal control to reasonably ensure compliance with enrollment reporting requirements. Condition.For one out of 40 students with status changes sampled, the College reported the change in status to NSLDS in 77 days (17 days later than required.) Cause. There was an error in the student?s social security number as reported to NSLDS by the College?s third-party servicer, the National Student Loan Clearinghouse, which prevented the status change from being accepted by the NSLDS. The College did not have a process in place to identify and address such errors. Effect. Status changes for records with erroneous demographic data may not be timely reported to the NSLDS. Questioned Costs. There are no questioned costs related to this finding. Statistical Validity of Sample. The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding. No similar finding was reported in the immediate prior year. Recommendation. We recommend the College enhance its policies and procedures to identify and correct records that are transmitted by NSLC but are not accepted by NSLDS because of erroneous demographic information. Views of Responsible Officials. The College concurs with this finding and has conferred with the National Student Clearinghouse and confirmed and documented the proper procedure for ensuring ejected file reports are reviewed, the coding understood, and errors are corrected by the Registrar?s office in a timely manner. If, after 45 days, the errors are not able to be corrected through NSC, the Registrar?s office will alert the Financial Aid Office so that the records can be manually updated onto NSLDS before the 60-day reporting deadline expires.