Holy Cross College

Information on the Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; Federal Work-Study Program, CFDA 84.033; Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268. Program Year – July 1, 2024 – June 30, 2025 Criteria for Specific Requirement – The Department of Education requires the College to report the disbursement dates and amounts on student ledges that match the disbursement dates and amounts reported to the Common Origination and Disbursement (COD) (685.301). Condition – During our testing, we noted 17 of the 25 disbursements tested had incorrect Pell and/or Direct Loan disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs – None – nonmonetary finding Context – The College did not have an official policy outlining the steps for updating these dates and turnover in the department that handles this reporting. Cause – The College does not have an official policy outlining the steps for updating these dates and turnover in the department that handles this reporting. Effect – The College is not in compliance with Department of Education regulations. Identification as a Repeat Finding – N/A Recommendation – We recommend the College evaluate its procedures and policies around reporting Pell and Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions – The College implemented a new financial aid system in FY26 which includes built in controls to detect and flag disbursement date discrepancies throughout the disbursement process. The reconciliation files generated from the new system include a comparison of disbursement dates which makes any differences easy to see and rectify.

Information on the Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; Federal Work-Study Program, CFDA 84.033; Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268. Program Year – July 1, 2023 – June 30, 2024 Criteria for Specific Requirement – Special Tests and Provisions – Return of Title IV Funds – Return 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)). Condition – Return of Title IV funds from the College was not initiated to ED within the required timeframe. Questioned Costs – None – nonmonetary finding Context – Out of a sample of 4 students from a population of 18 students who were required to have a Return of Title IV Funds calculation performed during the year, the College did not initiate the Return of Title IV funds to ED within the required timeframe for one student. Our sample was not, and was not intended to be, statistically valid. Cause – Return of Title IV funds was not initiated to ED timely. This could have been a result of limited communication between those with direct knowledge of student withdrawals and those responsible for calculating and initiating the Return of Title IV funds. Effect – Return of Title IV funds was ultimately returned to ED but was not initiated timely Identification as a Repeat Finding – N/A Recommendation – We recommend the College ensure there is consistent communication between those with direct knowledge of student withdrawals and those responsible for calculating and initiating the Return of Title IV funds. Views of Responsible Officials and Planned Corrective Actions – The College has established a policy of governing the Return of Title IV funds for its students in prison. The policy better defines withdrawals for this unique student population, and institutes regular meetings at critical dates throughout the semester between the Director of the Moreau College prison initiative, the Registrar, Finance, the Office of Financial Aid, and the Vice President for Enrollment and Student Engagement to ensure student withdrawals from both the prison program as well as the residential campus are known and recorded, and the Return of Title IV funds process can be completed within the required timeframe. Additionally, the College continues to invest in its Office of Financial Aid through hiring of additional support and enrolling its senior administrators in the NASFAA Certified Financial Aid Administrator Program.

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268, Federal Perkins Loan Program, CFDA 84.038. Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? Under the Pell grant and loan programs, colleges must complete and return within 30 days the Enrollment Reporting roster file. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the college must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309). Condition ? Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required timeframe. Questioned Costs ? None. Context ? Out of a sample of 13 students from a population of 126 students who had changes in status during the year, NSLDS was not provided timely notification for two of the student status changes reviewed. Our sample was not, and was not intended to be, statistically valid. Effect ? NSLDS did not contain current information with respect to the student status of some students. Cause ? Information between the Clearinghouse and NSLDS was not updated timely. This could have been a result of the College?s data files not including the most recent information upon submission to the Clearinghouse. Identification as a Repeat Finding ? Yes. Recommendation ? We recommend the College monitor and evaluate the scheduled reporting dates to the Clearinghouse. Also, confirm or modify existing formal policies, procedures or processes for timely identification or reporting lines that need to be informed to ensure that status changes can be communicated to NSLDS timely. Finally, we recommend the College implement a secondary review process to ensure those students with status changes are being properly reflected within NSLDS after the submission is received.

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268, Federal Perkins Loan Program, CFDA 84.038; Federal Supplemental Education Opportunity Grant, CFDS 84.007; Federal Work Study Program; CFDA 84.033; Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement - Special Tests and Provisions - Disbursements to or on behalf of students Condition ? 34 CFR section 668.165 requires Holy Cross College to notify student, or parent in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Questioned Costs ? N/A Context ? A sample of 25 students was selected for testing out of a total population of 296 to determine written notifications were sent to students, or parents after disbursements. College did not complete the required notifications for 25 of the students selected for testing. Our sample selection was not, and was not intended to be, statistically valid. Effect ? Students or parents were not notified of disbursements or notified of their right to cancel all or a portion of the loan disbursement. Cause ? The Business Office experienced personnel turnover during the year, which in turn caused an oversight in sending disbursement notification letters as required. Repeating Finding ? N/A Recommendation ? College should establish process and controls to ensure disbursement notification letters are sent when required to ensure ongoing compliance.

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? The determination of Federal Student Financial Assistance aid is based on financial need. Financial need is generally defined as the student?s cost of attendance (COA) minus financial resources reasonably available. For Title IV programs, the financial resources available is generally the Expected Family Contribution (EFC) that is computed by the central processor and included on the student?s SAR and the ISIR provided to the institution. The College then awards the appropriate amount of need-based aid based on the student?s computed EFC, as well as their level of enrollment. 34 CFR section 668.42, FPL FWS and FSEOG. 34 CFR Sections 673.5 and 673.6; Direct Loan 42 CFR section 57.306(b); NFLP, 34 CFR section 686.21; TEACH and 34 CFR sections 690.61 ? 690.67; Pell. Condition ? Our testing resulted in one student being under awarded $2,775 of Pell when considering the student?s expected family contribution and cost of attendance. Questioned Costs ? $2,784 of Pell was under awarded. Context ? Out of a population of 156 students receiving Pell, a sample of 16 students was selected to ensure the College correctly calculated Pell amounts. Our testing resulted in one student?s Pell disbursement was not consistent with our calculation, and resulted in an under award of $2,784. Our sample selection was not, and was not intended to be, statistically valid. Effect ? A student was under awarded Pell based on their expected family contribution. Cause ? Management oversight in reviewing Pell calculations and ensuring that the students were receiving the proper Pell award amounts, based on expected family contributions. Identification as a Repeat Finding ? N/A Recommendation ? The College should implement additional controls to ensure Pell calculations are being calculated correctly based on expected family contributions.

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