John A. Logan College

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001, 2023-001) Federal Program Name Student Financial Assistance Program Project No. P063P220542, P063P230542, P007A221184, P007A231184, P033A221184, P033A231184 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: CFR section 685.309 (b)(2) requires the College to notify the lender within 30 days if it discovers that a student who has received a loan did not enroll or ceased to be enrolled on at least a half time basis. The College has 60 days to notify the lender if the next scheduled roster reporting date is within 60 days of the date of determination of status change. Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported to the Clearinghouse after withdrawing from the institution. Questioned Costs: None Context: Of the forty (40) students tested for Enrollment Reporting purposes, two (2) students were not reported within the 60-day time frame. Effect: Inaccurate information may be included in the Submittal File or Enrollment Updated to NSLDS. Cause: The College’s Student Information System (SIS), Jenzabar One, generates Clearinghouse files for term reporting with pre-populated withdrawal dates. After receiving the audit finding, the College determined that its SIS was using the incorrect date for some withdrawals. The SIS was using the school’s determination date instead of the withdrawal date for reporting which was the cause of the finding. Recommendation: We recommend the College establish procedures to ensure that accurate and timely information is report to NSLDS. Management’s Response: Management agrees with the finding.

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001 and 2023-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported to the Clearinghouse after withdrawing from the institution. Plan: After contacting Jenzabar One, the College has determined it cannot alter the pre-made Clearinghouse report; however, the College can alter its withdrawal process to ensure accurate withdrawal dates are reported in the correct area within the SIS. Admissions and Records will modify withdrawal and school determination dates, so the SIS gathers the correct information to be reported for future reporting. The Registrar will also work with and crosscheck students with Financial Aid to ensure all students who attended, but dropped before census, will be reported to the Clearinghouse. Anticipated Date of Completion: January 2025 Name of Contact Person: Dr. Stephanie Hartford, Provost

2023-001

Finding No. 2023-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001) Federal Program Name Student Financial Assistance Program Project No. P063P210542, P063P220542, P007A221184, P033A221184 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: CFR section 685.309 (b)(2) requires the College to notify the lender within 30 days if it discovers that a student who has received a loan did not enroll or ceased to be enrolled on at least a half time basis. The College has 60 days to notify the lender if the next scheduled roster reporting date is within 60 days of the date of determination of status change. Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported within the 60 day requirement. Questioned Costs: None Context: Of the forty (40) students tested for Enrollment Reporting purposes, two (2) students were not reported within the 60-day time frame. Effect: Inaccurate information may be included in the Submittal File or Enrollment Updated to NSLDS. Cause: A graduation date was backdated when the grade was changed from an incomplete to an A upon completion of graduation requirements by the student after the end of the term. Also, an ERP system error caused a student who had graduated in one semester and then re-enrolled full-time the next semester to be missed in the Clearinghouse enrollment reporting for the previous semester. Recommendation: We recommend the College establish procedures to ensure that accurate and timely information is report to NSLDS. Management’s Response: Management agrees with the finding.

Finding No. 2023-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported within the 60 day requirement. Plan: Admissions and Records will no longer award degrees after a two-week grade period following each semester’s conferred date. All students who do not apply or do not meet the qualifications to grade on this date will be awarded at the end of the following term. A letter of completion may be provided to students who complete degree requirements during the course of a semester. Applicable programs have been notified of this change. In addition, the final Clearinghouse submission with degrees will be submitted and validated prior to any submissions for the next term. Additionally, the degree submission list posted to the Clearinghouse will be compared to the final graduate list generated in Institutional Research to ensure the lists match. Anticipated Date of Completion: December 2023 Name of Contact Person: Stephanie Hartford, Provost

2022-001

Finding No. 2022-001: Controls Over Student Financial Assistance Special Tests and Provisions ? Enrollment Reporting Federal Program Name Student Financial Assistance Program Project No. P063P200542, P063P210542, P007A211184, P033A211184 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: CFR section 685.309 (b)(2) requires the College to notify the lender within 30 days if it discovers that a student who has received a loan did not enroll or ceased to be enrolled on at least a half time basis. The College has 60 days to notify the lender if the next scheduled roster reporting date is within 60 days of the date of determination of status change. Condition: During the compliance testing of ?Special Tests and Provisions? requirements related to Enrollment Reporting, we noted the following exceptions: ? Two (2) students were reported as dropped when they should have been reported as withdrawn. ? One (1) student was missed being reported to the Clearinghouse. Questioned Costs: None Context: Of the forty (40) students tested for Enrollment Reporting purposes, one (1) was not reported within the 60-day time frame and two (2) were not reported with the correct status. Effect: Inaccurate information may be included in the Submittal File or Enrollment Updated to NSLDS. Cause: When the student withdrew during the 100% refund period, the College did not contact faculty to obtain and record the specific last date of attendance within that period of time. The College failed to implement additional internal checks for all undergraduate students to ensure the student?s division type was correctly coded and reported to the Clearinghouse. Recommendation: We recommend the College establish procedures to ensure that accurate and timely information is report to NSLDS. Management?s Response: Management agrees with the finding.

Finding No. 2022-001: Controls Over Student Financial Assistance Special Tests and Provisions ? Enrollment Reporting Condition: During the compliance testing of ?Special Tests and Provisions? requirements related to Enrollment Reporting, we noted the following exceptions: ? Two (2) students were reported as dropped when they should have been reported as withdrawn. ? One (1) student was missed being reported to the Clearinghouse. Plan: Two (2) students withdrew during the 100% refund period but were reported as dropped in our Enrollment Reporting. The College has implemented a process to always record a last date of attendance even when a student withdraws prior to the census date and receives a full refund. If a student never attended, the day prior to the start of the term is recorded. If a student attends even one class period, that date is recorded in the student information system where financial aid can use the date in their return of funds calculation. The other exception was a student who was incorrectly classified in the student information system and was therefore not included in the National Student Clearinghouse file. Reports have been created to ensure students with undergraduate enrollment for the term are accurately coded in the system in order to be included in National Student Clearinghouse enrollment files for the term. Anticipated Date of Completion: October 2022 Name of Contact Person: Melanie Pecord, Provost

Finding No. 2022-002: Controls Over Student Financial Assistance ? Disbursements to Students Federal Program Name Student Financial Assistance Program Project No. P063P200542, P063P210542, P007A211184, P033A211184 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: The Student Financial Aid Handbook states a Title IV credit balance is created when the Title IV funds credited to the student?s account exceeds the amount assessed to the student for allowable charges associated with the payment period. When paying the credit balance owed to the student the school must pay the balance owed within 14 days from the time it was created. Condition: During our testing it was noted that three (3) students? refunds were not processed within the required 14 days. Questioned Costs: None Context: During our student financial aid testing, it was noted that three (3) of out seventy-one (71) students? credit balances were not returned within the required time frame. Effect: The student did not receive a refund within the required 14 days. Cause: The Bursar Office was using a report built to identify only students with credit balances of $5 or more in a current semester and were reviewing past semesters on a monthly basis. Recommendation: We recommend the College implement a review process over application of funds to student accounts. Management?s Response: Management agrees with the finding.

Finding No. 2022-002: Controls Over Student Financial Assistance ? Disbursements to Students Condition: During our testing it was noted that three (3) students? refunds were not processed within the required 14 days. Plan: John A. Logan College (JALC) concurs with Finding No. 2022-002. The Bursar Office staff has been made aware of the condition and have implemented procedures to avoid this situation in the future. The Bursar Office has created a report to identify all refunds regardless of amount or semester and now runs this report on a weekly basis. Refund amounts are then sent out within the 14-day time period. Anticipated Date of Completion: November 2022 Name of Contact Person: Stacy Buckingham, Vice-President of Business Services and CFO

Finding No. 2021-001: Controls Over Student Financial Assistance Special Tests and Provisions ? Return of Funds (Repeated from Findings 2020-001, 2019-001 and 2018-001) Federal Program Name Student Financial Assistance Program Project No. P007A201184, P033A201184, P063P190542, P063P190542 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: The Student Financial Aid Handbook states that if a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, the school must perform an R2T4 calculation to determine the amount of Title IV assistance earned by the student. Condition: During the compliance testing of ?Special Tests and Provisions? requirements related to Return of Funds, we noted the following exceptions: ? For twelve (12) students the incorrect semester end date was used in the calculation. ? For thirteen (13) students the amount of break days used in the calculation was incorrect. Questioned Costs: None Context: In the Return of Funds calculation, twenty-five (25) of the twenty-five (25) returns were calculated incorrectly. Effect: Funds sent back to the Department of Education could be calculated incorrectly. Cause: The Return of Funds calculation errors were due to oversight over the dates used in the calculations. Recommendation: We recommend the College implement a review process over the Return of Funds calculation. Management?s Response: Management agrees with the finding.

Finding No. 2021-001: Controls Over Student Financial Assistance Special Tests and Provisions ? Return of Funds (Repeated from Findings 2020-001, 2019-001 and 2018-001) Condition: During the compliance testing of ?Special Tests and Provisions? requirements related to Return of Funds, we noted the following exceptions: ? For twelve (12) students the incorrect semester end date was used in the calculation. ? For thirteen (13) students the amount of break days used in the calculation was incorrect. Plan: John A. Logan College (JALC) concurs with Finding No. 2021-001. Extensive training has been conducted on the Return of Title IV Funds regulations. The Federal Student Aid Handbook has been reviewed in detail as a source document to ensure all requirements of the Return of Title IV Funds regulations have been addressed. The correct beginning and ending dates of scheduled breaks greater than five days in length have been recorded in PowerFAIDS, JALC?s financial aid system of record. The financial aid staff have a clear understanding that scheduled breaks must include weekends preceding and following the scheduled break provided no classes are offered on the weekends. In addition, any faculty that deviate from the college catalog?s academic calendar must have prior approval by the Assistant Provost for Academic Affairs. A validation process will be created with a signoff from the Assistant Provost for Student Affairs and Associate Manager for Curriculum and Instruction. Anticipated Date of Completion: March 2022 Name of Contact Person: Melanie Pecord, Provost

2020-001

Finding No. 2021-002: Controls Over Student Financial Assistance Special Tests and Provisions ? Disbursements to Students Federal Program Name Student Financial Assistance Program Project No. P007A201184, P033A201184, P063P190542, P063P190542 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: The Student Financial Aid Handbook states that if a recipient of Title IV grant or loan funds has a prior year balance, it may use the current year award to satisfy prior year balances of not more than $200. A ?prior-year? is any award year or loan period prior to the current one, as applicable. The remaining award, if any, should be returned to the students within fourteen (14) days of the day the credit balance occurred. Condition: During our testing it was noted that one student?s Title IV award was used to pay prior year charges in the amount of $827. This should have been limited to $200. The remaining $627 would have created a credit balance on the student?s current year account which the College would have been required to return to the student within 14 days. Because the school did not correctly apply the funds, the 14 day requirement was not met. Questioned Costs: None Context: During our student financial aid testing, it was noted that in one (1) instance out of forty (40) the incorrect amount of award was applied to the students? prior year balance due. Specifically, $827 of the current year award was applied to a prior year balance. Per the student financial aid guidance, this should be limited to $200. Effect: The student did not receive a refund within the required 14 days. Cause: Oversight of the student financial aid requirements. Recommendation: We recommend the College implement a review process over application of funds to student accounts. Management?s Response: Management agrees with the finding.

Finding No. 2021-002: Controls Over Student Financial Assistance Special Tests and Provisions ? Disbursements to Students Condition: During our testing it was noted that one student?s Title IV award was used to pay prior year charges in the amount of $827. This should have been limited to $200. The remaining $627 would have created a credit balance on the student?s current year account which the College would have been required to return to the student within 14 days. Because the school did not correctly apply the funds, the 14 day requirement was not met. Plan: John A. Logan College (JALC) concurs with Finding No. 2021-002. The Bursar Office staff have been made aware of the condition and have been given a copy of Volume 4, Chapter 2 of the 2020- 2021 Federal Student Aid Handbook as it relates to paying prior-year charges with Title IV funds. The Bursar Office staff, Controller, and Financial Aid Office have a clear understanding that the College may only use current year Title IV funds to satisfy qualifying prior-year charges of not more than $200, regardless of student or parent authorization. Any remaining credit balance will be refunded to the student within 14 days. The Bursar Office will not deviate from this regulation. Anticipated Date of Completion: November 2021 Name of Contact Person: Stacy Buckingham, Vice-President of Business Services and CFO

Finding No. 2021-003: Controls Over Student Financial Assistance Consumer Information Reporting Federal Program Name Student Financial Assistance Program Project No. P007A201184, P033A201184, P063P190542, P063P190542 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: The Student Financial Aid Handbook requires that if a school has an intercollegiate athletic program, the school is to make prospective students aware of its commitment to providing equitable athletic opportunities for its male and female students. The annual report commonly referred to as the Equity in Athletics (EADA) report must include specific information related to students that receive financial aid. The College did file the reporting timely, but did not include the following information related to student financial aid: ? The number of students above who received athletically related student aid, categorized by gender within each sport. ? The completion or graduation rate and, if applicable, transfer out rate of the entering students described in 668.45(a)(1) who received athletically related student aid, categorized by race and gender. ? The average completion or graduation rate and, if applicable, transfer-out rate for the four most recent completing or graduating classes of entering students described in 668.45(a)(1), (3), and (4), categorized by race and gender. ? The average completion or graduation rate and, if applicable, transfer out rate of the four most recent completing or graduating classes of enter students described in 668.45 (a)(1) who received athletically related student aid, categorized by race and gender within each sport. Condition: After reviewing the EADA report, it was noted that the requirements above were not met. Questioned Costs: None Context: The EADA report was posted by the required deadline but did not include all information of the required to be reported. Effect: The College was not in compliance with the consumer information EADA reporting requirements.

Finding No. 2021-003: Controls Over Student Financial Assistance Consumer Information Reporting Criteria/Specific Requirement: The Student Financial Aid Handbook requires that if a school has an intercollegiate athletic program, the school is to make prospective students aware of its commitment to providing equitable athletic opportunities for its male and female students. The annual report commonly referred to as the Equity in Athletics (EADA) report must include specific information related to students that receive financial aid. The College did file the reporting timely, but did not include the following information related to student financial aid: ? The number of students above who received athletically related student aid, categorized by gender within each sport. ? The completion or graduation rate and, if applicable, transfer out rate of the entering students described in 668.45(a)(1) who received athletically related student aid, categorized by race and gender. ? The average completion or graduation rate and, if applicable, transfer-out rate for the four most recent completing or graduating classes of entering students described in 668.45(a)(1), (3), and (4), categorized by race and gender. ? The average completion or graduation rate and, if applicable, transfer out rate of the four most recent completing or graduating classes of enter students described in 668.45 (a)(1) who received athletically related student aid, categorized by race and gender within each sport. Condition: After reviewing the EADA report, it was noted that the requirements above were not met. Plan: John A. Logan College (JALC) concurs with Finding No. 2021-003. The Athletic Director and office of Institutional Effectiveness staff have been made aware of the condition and have been given a copy of 34 CFR 668 as it relates to EADA Consumer Information reporting. We have met with involved staff members and will post a report for the academic year ending summer 2021 by the anticipated date of completion below. Procedures will be put in place to post this disclosure annually by October 15th. The report will be posted on the College?s public facing website. Anticipated Date of Completion: June 30, 2022 Name of Contact Person: Greg Starrick, Athletic Director

Finding No. 2020-001: Controls Over Student Financial Assistance Special Tests and Provisions (Repeated from Findings 2019-001 and 2018-001) Federal Program Name Student Financial Assistance Program Project No. P063P180542, P063P190542, P033A191184, P007A191184 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: CFR section 685.309 (b)(2) requires the College to notify the lender within 30 days if it discovers that a student who has received a loan did not enroll or ceased to be enrolled on at least a half time basis. The College has 60 days to notify the lender if the next scheduled roster reporting date is within 60 days of the date of determination of status change. When performing the Return of Funds calculation, the Student Financial Aid handbook states that when determining the institutional charges to calculate the portion of unearned Title IV aid that the school is responsible for returning, institutional charges may not be reduced if other sources of aid are used to pay the charges. Condition: During the compliance testing of ?Special Tests and Provisions? requirements, we noted the following exceptions: ? Eight (8) students were not reported within the 60-day time frame. ? Four (4) students? Return of Funds calculation was incorrect. The MAP grant was reduced from the institutional charges, resulting in the incorrect amount of funds being returned to the Department of Education. Questioned Costs: None Context: Of the seventy-one (71) students tested for Enrollment Reporting purposes, eight (8) were not reported within the 60-day time frame. In the Return of Funds calculation, four (4) of twenty-five (25) returns were calculated incorrectly. Effect: Inaccurate information may be included in the Submittal File or Enrollment Update to the NSLDS. Funds sent back to the Department of Education could be calculated incorrectly. Cause: Late NSLDS enrollment notifications are caused by faculty failing to report students who stopped attending during the semester to the Office of Admissions and Records within the required time-frame as outlined in the College?s Administrative Withdrawal Procedure. This procedure requires faculty to report attendance and/or attendance status at the census date and at midterm, and also allows faulty to request the withdrawal of a student at any point in the semester if certain attendance limits are not met. The Return of Funds calculation errors were caused by reliance on State guidance instead of federal requirements, which take precedent. Recommendation: We recommend the College establish procedures to ensure that accurate and timely information is reported to NSLDS. Additionally, we recommend the College implement a review process over the Return of Funds calculation. Management?s Response: Management agrees with the finding.

Finding No. 2020-001: Controls Over Student Financial Assistance Enrollment Reporting Condition: During the compliance testing of ?Special Tests and Provisions? requirements, we noted the ollowing exceptions: ? Eight (8) students were not reported within the 60-day time frame. ? Four (4) students? Return of Funds calculation was incorrect. The MAP grant was reduced from the institutional charges, resulting in the incorrect amount of funds being returned to the Department of Education. Plan: Admissions and Records is actively working with the Instructional Division to educate faculty on the importance of correctly reporting students who stop attending and/or participating during the semester. The College currently requires faculty to report student attendance at the census date and pass/fail grades at midterm. The current Administrative Withdrawal Procedure at the College allows faculty to request the withdrawal of students who fail to attend or participate (for online courses) for a period equal to one week of the course. Moving forward, the College will make the Administrative Withdrawal Procedure mandatory for faculty. Additionally, staff will continue to use faculty orientation sessions to stress the importance of timely reporting of students who stop attending or participating during the course of the semester. As as added reminder, Admissions and Records will send weekly emails to full-time and adjunct faculty requesting non-attending students be withdrawn. The Instructional Division has further determined that failure of faculty to report students in a timely manner will be reflected in annual performance evaluations. Through an institution wide effort, the College believes we can better meet the guidelines for reporting withdrawn students within the 60-day required window. The Financial Aid Office has changed the way the Return of Funds are calculated beginning with the 2020-2021 school year. Other sources of aid, including the Map grant, are no longer reduced from the institutional charges. Anticipated Date of Completion: Immediately Name of Contact Person: Melanie Pecord, Vice President of Instructional Services

2019-001

Finding No. 2019-001: Controls Over Student Financial Assistance Enrollment Reporting Federal Program Name Student Financial Assistance Program Project No. P063P180542, P063P170542, P033A181184, P007A171184, P007A181184 CFDA No. 84.063, 84.007, 84.033 Federal Agency U.S. Department of Education Criteria/Specific Requirement: CFR section 685.309 (b)(2) requires the College to notify the lender within 30 days if it discovers that a student who has received a loan did not enroll or ceased to be enrolled on at least a half time basis. The College has 60 days to notify the lender if the next scheduled roster reporting date is within 60 days of the date of determination of status change. Condition: During the compliance testing of ?Special Tests and Provisions ? Enrollment Reporting? requirements, we noted the following exceptions: ? Sixteen (16) out of 71 students who had graduated were not reported as graduated, but were reported as withdrawn. NSLDS reporting guide states, ?The implementation of the 150% subsidized loan limit makes the reporting of Withdrawn `W? or Graduated `G? status even more critical.? ? Eighteen (18) students were reported as graduated, but not within the 60 day time period. ? One student selected for testing was not reported to the Clearinghouse. Questioned Costs: None Context: Exceptions were noted in 35 of the 71 students tested. Effect: Inaccurate information may be included in the Submittal File or Enrollment Update to the NSLDS. Cause: Lack of oversight in the Enrollment Report to NSLDS. Recommendation: We recommend the College establish procedures to ensure that accurate and timely information is reported to NSLDS. Management?s Response: Management agrees with the finding.

Finding No. 2019-001: Controls Over Student Financial Assistance Enrollment Reporting Condition: During the compliance testing of ?Special Tests and Provisions ? Enrollment Reporting? requirements, we noted the following exceptions: ? Seventeen (17) out of 68 students who had graduated, were not reported as graduated, but were reported as withdrawn. NSLDS reporting guide states, ?The implementation of the 150% subsidized loan limit makes the reporting of Withdrawn `W? or Graduated `G? status even more critical.? ? Eighteen (18) students were reported as graduated, but not within the 60 day time period. ? One student selected for testing was not reported to the Clearinghouse. Plan: In response to the audit finding, the College has taken steps to ensure accurate and timely reporting to the National Student Clearinghouse and NSLDS in relation to reporting a status of graduated. To facilitate timely reporting, the College will now submit the Degree Verify file at the same time as our end-of-term Enrollment file. We will closely monitor email communication to ensure the file is received and accepted. To ensure accurate reporting, Admissions and Records will implement a two-step verification: ? Prior to submission, the Admissions and Records Office will select a sample and verify the accuracy of data with the file, as well as match the total number of records to the number of degrees awarded for that term. ? After the submission is posted, Admissions and Records will login to the Clearinghouse website and verify the graduated status has been updated for a representative sample. In addition to these steps, the College staff involved in the reporting process will participate in online learning courses offered by the National Student Clearinghouse related to Enrollment Reporting and Degree Verification. Admissions and Records will also coordinate with the IT Department to ensure submission files are correctly formatted to avoid file submission errors and delays. Additionally, the Associated Dean for Admissions and Records will ensure student errors related to graduation from fiscal year 2019 are corrected through an updated submission file to the Clearinghouse in December 2019. Anticipated Date of Completion: Immediately Name of Contact Person: Brad McCormick, Vice President for Business Services and College Facilities

2018-001, 2018-002