Oakland Community College

CFDA Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - P268K201648, P063P191648 and P033A192059 Pass-through Entity - U.S. Department of Education Finding Type - Significant deficiency Repeat Finding - Yes Prior year reference number: 2019-002 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (34 CFR 668.22(j)(1)). Condition - Of the calculations for 45 students originally selected for return of Title IV calculation testing, two calculations were not performed after the student's withdrawal. An additional 35 students were identified by management's analysis of the noted condition. An additional sample of 15 students tested after the identification of the condition described above identified a further two calculations that were not performed within 45 days from the determination of the students' withdrawal. Questioned Costs - $39,058, related to the 37 calculations identified in the first condition above. The second condition identified did not have any questioned costs. Identification of How Questioned Costs Were Computed - The questioned costs were determined by totaling the unearned aid received by the original 2 students, which was not returned timely. Additionally, management performed an analysis to identify other students of the same condition to ultimately determine total known questioned costs. Context - Of the calculations for 45 students selected for return of Title IV calculation testing, two calculations were not performed after the student's withdrawal. An additional 35 students were identified by management's analysis of the noted condition. Total unearned aid not identified by management and not returned timely was $39,058. Cause and Effect - Controls over the review of calculations performed were inadequate to ensure the population of students requiring calculations was complete and controls were insufficient to ensure that all required calculations were performed timely. As a result, the return of funds for 37 students was not completed prior to the identification of the noted condition by the audit. Additionally, for other calculations, though funds were ultimately returned prior to identification of the noted condition, certain calculations were not performed timely. Recommendation - The College should implement additional controls to ensure all necessary return of Title IV calculations are completed and that such calculations and returns are done so in a timely manner. Views of Responsible Officials and Corrective Action Plan - The College agrees with the finding identified and has instituted plans to prevent future occurrence. It is accepted by community college financial aid departments, the Return to Title IV (R2T4) federal requirement demands a high level of continuous, focused attention. The College has dedicated staff members and provided training to ensure compliance. The financial aid manager charged with this responsibility has earned the National Association of Student Financial Aid Administrators (NASFAA) credential in R2T4 and possesses an additional 11 NASFAA credentials for other financial aid programs. The financial aid specialists working in this area have also earned the NASFA credential in R2T4. The plan is to bring these three qualified staff members together in a centralized location to collaborate and focus on the accuracy and details required for compliance. In addition, the College has employed a third-party consultant to review the financial aid department staffing, processes, and procedures. We will use the recommendations from this report to improve operational procedures and create efficiencies throughout the department. The College wants to acknowledge the challenges presented to the financial aid department as a result of the pandemic. Beginning on March 13, 2020, the financial aid department began a journey down an uncharted path of multiple federal changes and waivers to current regulations. At the same time, the College prepared to quickly transition to a remote environment because of COVID-19. On March 24, 2020, Michigan?s Governor Whitmer issued the stay-at-home executive order, and by March 27, 2020, the full financial aid office had become virtual.

CFDA Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - P268K201648, P063P191648, and P033A192059 Pass-through Entity - U.S. Department of Education Finding Type - Significant deficiency Repeat Finding - Yes - 2019-001 Criteria - An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2) and 34 CFR 685.309). A school must update the National Student Loan Data System (NSLDS) within 30 days of a student status change, unless the school expects to submit its next enrollment report to the NSLDS within 60 days (34 eCFR 685.309). Condition - The student status changes for certain students with status changes (graduated students, an official withdrawal, and a status change from full time to less than half time) were not reported within 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the sample of 40 student status changes selected for enrollment reporting testing, 4 students (relating to graduation status changes following the winter semester) were not reported within the required 60-day period. In addition, 1 student who officially withdrew and 1 student whose status changed from full time to less than half time were not reported within the required 60-day period. Cause and Effect - Controls were inadequate to ensure all student status changes were reported in a timely fashion. As a result, status changes were reported late. Recommendation - The College should implement controls to ensure timely student status change reporting. Views of Responsible Officials and Planned Corrective Actions - The College agrees, with slight reservation, with the finding identified and has plans to prevent future occurrence. Following the finding in last year?s audit, Oakland Community College implemented steps to improve processes for enrollment and degree reporting. The National Student Clearinghouse?s (NSC) two-pronged verification process for graduation reporting continues to complicate reporting to the National Student Loan Data System (NSLDS) due to the lengthy and complex validation process that must occur through the NSC website. In order to gain a greater understanding of the College?s reporting responsibilities and timeline, the registrar?s office initiated several communications with the NSC Audit Resource Center to gain their experiences and professional interpretation of Department of Education guidelines. Following their expertise and guidance, the College instituted new measures to ensure graduations were reported to NSLDS with 60 days from the date the College identified graduation requirements had been completed. The interpretation of continuous summer term enrollment and when graduations requirements had been completed has been a point of debate. In the future, the College will take the more conservative interpretation, as defined by our audit firm. The College continues to work on process and technology improvements and continues to engage in regular discussion with the experts at the NSC Audit Resource Center. Additionally, the College has initiated discussions with peer institutions to share best practices and identify process efficiencies to ensure timely reporting of all enrollment and graduation status changes.

CFDA Number, Federal Agency, and Program Name - 84.268 and 84.063, Department of Education, Student Financial Aid Cluster None Federal Award Identification Number and Year - P268K181648, P063P171648 Pass-through Entity - U.S. Department of Education Finding Type - Significant deficiency Repeat Finding - Yes - 2018-001 Criteria - Institutions shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2) and 34 CFR 685.309). A school must update the National Student Loan Data System (NSLDS) within 30 days of a student status change, unless the school expects to submit its next enrollment report to the NSLDS within 60 days (34 eCFR 685.309). Condition - The student status changes for certain students who graduated from the College were not reported within 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students selected for enrollment reporting testing, 15 students were not reported within the required 60-day period. This impacted only graduated students. Cause and Effect - A control was lacking to ensure proper reporting of graduated students was timely to the NSLDS. As a result, certain graduated students were not reported timely. Recommendation - The College should implement controls to ensure all graduated students are reported timely to the NSLDS.

CFDA Number, Federal Agency, and Program Name - 84.268 and 84.063, Department of Education, Student Financial Aid Cluster None Federal Award Identification Number and Year - P268K181648, P063P171648 Pass-through Entity - U.S. Department of Education Finding Type - Significant deficiency Repeat Finding - No Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she have attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal. (34 CFR 668.22(j)(1)) Condition - One student's return was completed later than 45 days from the determination of the student's withdrawal. The delay in the return was identified by management and was corrected subsequent to the passing of the 45-day requirement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students selected for return of Title IV calculation testing, one calculation was completed greater than 45 days from the determination of the student's withdrawal. Cause and Effect - Controls over the review of calculations performed were inadequate to ensure that all students' return of Title IV calculations were completed timely. As a result, the return of funds was not completed timely. Recommendation - The College should implement additional controls to ensure all return of Title IV calculations are completed timely.

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