PENNSYLVANIA INSTITUTE OF TECHNOLOGYHigher Education

Finding 2023-001: Eligibility for Subsidized Direct Loans ALN Number: 84.268 Federal Program: Federal Direct Student Loans Federal Agency: U.S. Department of Education Federal Award Number: P268K230616 Federal Award Year: July 1, 2022 - June 30, 2023 Pass-Through Entity: Not applicable Repeat Finding: Not applicable Criteria: A Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Act [34 CFR 685.200(a)(2)(i)]. Condition/Context: For 2 of the 40 students tested for eligibility, the students received subsidized direct loan disbursements when their financial need was $0 based on the student expected family contribution (EFC) being in excess of the cost of attendance. Review of the College's student population for the 2022-2023 academic year was completed and it determined there were no other students that received need based financial aid in excess of their financial need. Cause: Determination of student aid for their first term was completed with the EFC indicating $0 in the student aid packaging system in error along with the incorrect amount of weeks and months in academic year, resulting in the student receiving a subsidized loan disbursement. In the following student semester, the EFC, weeks, and months in academic year was corrected in the system and the student award for that term did not disburse a subsidized loan disbursement. Effect: Students received subsidized direct loans when not eligible based on student financial need. The students tested could have been awarded unsubsidized direct loans in accordance with the eligibility for unsubsidized direct loans. Questioned Costs: Questioned costs for the two students tested is $2,667 of subsidized direct loans. Sample was not statistically valid. Recommendation: The College should ensure that all EFC information from the ISIR is entered in to the student aid packaging system before the student aid award is calculated. Views of Responsible Officials and Planned Corrective Actions: The College agrees with this finding. In review of the student records, the student aid packaging system at the time of aid determination indicated an EFC of $0 and months and weeks in academic year being zero. However, the FASFA was completed and the ISIR EFC amount was known at the time of the packaging and loan issued due to the cost of attendance not calculating correctly at time of packaging. The student aid packaging system parameters ensure that if need amount is $0 the system will stop a subsidized direct loan from being awarded. The weeks and months in academic year information was corrected in their next term and a subsidized loan was not awarded. Error appears related to only their first loan issued.  The allowance of subsidized loans was due to user error because the months and weeks enrolled in academic year were showing as zero. The College has re-trained its staff on the sequence of processing and ensure that inputs for months and weeks in academic year are correct. The College also worked with their student information system to ensure the set up for academic year definitions for cost of attendance calculations are set to be automatic for proper calculations. The College made an internal report in order to review all student financial need for the 2022-2023 academic year in February 2024 and determined there were no additional students awarded need based aid in excess of their financial need. The College will continue to use this report every term to review need. For the 2 students that received subsidized loans in error, their loans were refunded in March 2024.

Finding 2023-002: Enrollment Reporting - Significant Deficiency ALN Number: 84.063; 84.268 Federal Program: Federal Pell Grant Program; Federal Direct Student Loans Federal Agency: U.S. Department of Education Federal Award Number: P063P220616; P268K230616 Federal Award Year: July 1, 2022 - June 30, 2023 Pass-Through Entity: Not applicable Repeat Finding: Not applicable Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS. [Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309] Condition/Context: For 1 of the 25 students tested, the effective date of the change in status of the campus level reporting and program level reporting in the NSLDS did not agree with College's records. Cause: The date of determination of the change in student status was entered as the effective date of the change in status in error. Effect: The effective date of the change in student status to withdrawn was reported in error to the NSLDS. Questioned Costs: There are no questioned costs associated with this finding. Sample was not statistically valid. Recommendation: The College should have someone independent of the preparer review the NSLDS roster file to check the effective date of change in status is in agreement with the College's records. Views of Responsible Officials and Planned Corrective Actions: The College agrees with this finding. Academic Records Office personnel were re-trained. Also, a report has been written to be run after the Student Status Confirmation Report (SSCR) procedure is run in the student financial aid system, that flags when a "Last Date of Attendance (LDA)" and NSLDS Withdrawal Date differ. Those cases can be troubleshooted and fixed, the SSCR rerun, and that updated file uploaded.

Finding 2022-001: HEERF Funds Reporting and Public Posting Federal Program: COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund - Student Aid Portion/ Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable ALN Number: 84.425E/84.425F Federal Award Number: P425E200999 / P425F200554 Federal Award Year: June 30, 2022 Repeat Finding: 2021-001 Criteria: Beginning on May 6, 2020, the Department of Education (ED) required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED decreased the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020 and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30 and December 31, March 31, June 30). 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. Institutions must post this quarterly report form no later than 10 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 post the information required in relation to the Student Aid Portion under CRRSAA and ARP (HEERF II and III) to the College's website within the required time frame for any period within fiscal year 2022. The College did not post the quarterly budget and expenditure reporting was not updated within 10 days after the quarters ended 12/31/2021 and 3/31/2022. In addition, the College did not designate an individual to review the information posted to the College's website. Sample was not statistically valid. 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 and Institutional Portion, nor designate an individual to review postings of the student aid portion information posted to the College's website. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: The College should assign an individual to track reporting requirements of awards to ensure the College is in compliance and identify a designated reviewer for the information posted to the College's website. The College should post the information required under the Student Aid Portion to its website in accordance with the ED guidelines. Views of Responsible Officials and Planned Corrective Actions: Officials at the school are aware of the reporting requirements and deadlines related to HEERF funding and have established a shared compliance calendar accessible by key staff to monitor this activity. The College updated its website on October 15, 2022 with the information regarding the Student Aid Portion distributed under HEERF II and III to its website in accordance with the ED guidelines. The College President and Director of Financial Aid will be responsible for ensuring that the website posting deadline has been met by monitoring this activity each quarter.

Federal Program: COVID-19 - Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Student Aid Portion/ Institutional Portion Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable ALN Number: 84.425E/84.425F Federal Award Number: P425E200999/ P425F200554 Federal Award Year: June 30, 2021 Criteria: Beginning on May 6, 2020, the Department of Education (ED) required institutions that received a HEERF I Section 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED decreased the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). 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. Institutions must post this quarterly report form no later than 10 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 post the information required in relation to the Student Aid Portion under CRRSAA and ARP (HEERF II and III) to the College's website within the required time frame for any period within fiscal year 2021. The College did not post the quarterly budget and expenditure reporting was not updated within 10 days after the quarters ended 9/30/2020, 3/31/2021, and 6/30/2021. In addition, the College did not designate an individual to review the information posted to the College's website. 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 and Institutional Portion, nor designate an individual to review postings of the student aid portion information posted to the College?s website. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: The College should assign an individual to track reporting requirements of awards to ensure the College is in compliance and identify a designated reviewer for the information posted to the College?s website. The College should post the information required under the Student Aid Portion to its website in accordance with the ED guidelines. Views of Responsible Officials and Planned Corrective Actions: Officials at the school are aware of the reporting requirements and deadlines related to HEERF funding and have established a shared compliance calendar accessible by key staff to monitor this activity. The College will update its website with the information regarding the Student Aid Portion distributed under HEERF II and III to its website in accordance with the ED guidelines. The College President and Director of Financial Aid will be responsible for ensuring that the website posting deadline has been met by monitoring this activity each quarter.

Finding 2019-001: N. Enrollment Status Reporting CFDA No.: 84.268 Federal Direct Loan Program Award Year: July 1, 2018 - June 30, 2019 Federal Agency: U.S. Department of Education Federal Award Number: P268K190616 Pass Through Entity: Not applicable Criteria: Title IV regulations ( 34 CFR 685.309b))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: For one student selected, the effective date of enrollment status change that was reported to National Student Loan Data System (NSLDS) was not accurate and did not represent the date the student graduated. Additionally, the students change of enrollment status was not updated timely on NSLDS, within 30 days or received in a response to a roster file within 60 days. Cause: The College's controls failed to identify the error in student enrollment reporting allowing for inaccurate and reporting to NSDLS. Additionally, the roster file sent by the College to NSLDS contained information to update the affected students? records within 60 days. However, the NSLDS records were not updated in a timely manner. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment status, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Context: The change in student status for 1 of 40 students tested was not reported accurately reported to the NSLDS within the required time frame. A total of 264 students who were issued Federal Direct Student Loans separated from the College during fiscal year 2019. The sample is not considered statistically valid. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and enrollment statuses are reported to NSLDS within the required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to NSLDS to make sure they are accurate. Views fo Responsible Offical and Planned Corrective Action: The College corrected the inaccurate reporting for the student cited within this finding. In addition, the College updated procedures to insure that the inaccurate reporting problems are addressed and do not happen again. Initially the College procedure relied on monthly batch reporting in the MIS to report the status of students who separated from the College. Manual reporting in NSLDS was also done, but only included reporting of Withdrawals. Manual reporting has now been expanded to include graduates in response to the noncompliance case identified in the audit. Further it was determined that cancels who were initially reported as attending should also be included in the monthly manual reporting, to avoid any inaccurate reporting of separation dates in general. In addition, at the time graduates are manually reported to NSLDS, all graduation dates will be reviewed to confirm that they have correctly been reported. The College has reviewed the procedures with the relevant personnel to insure that they are fully informed regarding their role in NSLDS reporting.