COLLEGE FOR CREATIVE STUDIES

Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, Student Financial Assistance Cluster - ALN 84.268, Federal Direct Student Loans; ALN 84.063, Federal Pell Grant Program Federal Award Identification Number and Year - P268K222849, P063P212849 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Changes in a student's status are required to be reported accurately to the National Student Loan Data System (NSLDS) or the guarantee agency (Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309). Condition - The College did not accurately report the effective date of a students' status changes to the NSLDS or the correct status change to the NSLDS. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Of the 60 students selected for enrollment reporting testing, the effective date of the status change or the correct status for 4 students was not accurately reported. Cause and Effect - The College prepares enrollment reporting based on known student status changes. The College did not report the correct effective date for 3 students and the correct status for 1 student, resulting in a violation of accurate reporting requirements within the NSLDS. The College did not have a control in place to verify that the correct effective date was reported to NSLDS in the required time frame. Recommendation - The University should implement controls to ensure that the accurate effective date or status is reported to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Before pulling the enrolled student list for submission to the National Student Clearinghouse (NSC), the director of financial aid will run a debugging process created by the financial aid and information technology teams to identify any inaccuracies in student enrollment status to be easily identified and corrected. Implementing this debugging process in advance of finalizing the NSC Student Enrollment Report file will ensure all data submitted to NSC is accurate.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster, Department of Education - CFDA No. 84.268, Federal Direct Student Loans and CFDA 84.063, Federal Pell Grant Program Federal Award Identification Number and Year - P268K202849 (2020), P063P192849 (2020) Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - According to 34 CFR Section 685.309 for Direct Loans and Section 690.83 for Pell, changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the College's determination of a change or included in a student status confirmation report sent to NSLDS within 60 days of the College's determination of the status change. Condition - Certain student status changes were not reported to the NSLDS within 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 student status changes selected for enrollment reporting testing, including 15 graduations and 25 other status changes, status changes were not reported timely for 15 students. The status changes that were not reported timely related to students with status changes other than graduations. Cause and Effect - Several enrollment reports generated for submission to the NSLDS throughout the year did not accurately reflect student status changes occurring throughout the semester. As a result, certain status changes were not reported to the NSLDS within 60 days of the College's determination of the change. Recommendation - We recommend the College review its procedures for verifying that enrollment reports generated for submission to the NSLDS include all status changes. Views of Responsible Officials and Corrective Action Plan - On June 19, 2020, the director of financial aid was doing an internal audit when it was determined that certain student records have not been reported correctly to National Student Clearinghouse (NSC), which consequently were not updated in the NSLDS. As of July 7, 2020, the College was working with the NSC to update and correct winter 2020 enrollment records due to the identified issue. As of July 20, 2020, NSC rebuilt the student records in question and sent the records to NSLDS to be updated. As of August 6, 2020, NSLDS received the updated enrollment records from NSC, and all affected accounts have been updated appropriately. The College has reviewed the processes and steps to create the enrollment records to be sent to NSC. After review, documentation of the enrollment reporting process has been expanded to include the appropriate Colleague screen, NSC Parameter Definition (SITS), and the correct date reference for Census Date/Previous Census Date fields. In addition, the College?s IT department has developed an internal report that will isolate enrollment changes in between reporting periods to verify accuracy of the reports being sent to NSC. This will be implemented immediately, and the internal report and the export report to NSC will be cross referenced for accuracy.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - CFDA No. 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - If a student selected for verification fails to provide required documentation, an institution may not originate or disburse direct subsidized loan proceeds. The student also forfeits the Federal Pell Grant for the award year (34 CFR 668.60). As a result, per the Department of Education's Dear Colleague Letter GEN-04-03 Revised (November 2004), institutions completing a Return of Title IV Aid (R2T4) calculation may not include direct subsidized loans or Pell as "aid that could have been disbursed" for a student subject to verification who has withdrawn without providing all required verification documents. Condition - The College included aid subject to verification in the R2T4 calculation as "aid that could have been disbursed" for a student that did not provide the documents required for verification. Questioned Costs - $1,268 Identification of How Questioned Costs Were Computed - The questioned costs were determined by reperforming the R2T4 calculation using only Title IV aid not subject to verification as "aid that could have been disbursed". Context - Of the 14 students selected for R2T4 testing, the calculation was improper for one student. Cause and Effect - The College performed the student's R2T4 calculation in a timely manner after the date of withdrawal assuming that the student would ultimately complete verification before the required time period expired. However, when the student did not provide the verification documents within the required time period, the College did not have a control in place to revise its calculation and return Title IV funds accordingly based on the revised eligible aid amount. Recommendation - We recommend the College review its R2T4 policies and procedures to ensure that the calculation of "aid that could have been disbursed" is accurate.

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