State Fair Community College

2020-001 - Special Test and Provisions ? Enrollment Reporting Criteria: The U.S. Department of Education requires the College to update changes in student enrollment status, report the date the enrollment status was effective, and submit changes electronically with the National Student Loan Data System (NSLDS) website in accordance with 34 CFR 682.610 and 34 CFR 685.309. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition: The College did not have procedures in place to ensure students who have withdrawn were being reported to the Department of Education. Context: A sample of 40 students revealed that enrollment status was not reported within the required timeframe for one student. Effect: The College was not in compliance with the timely reporting requirements of enrollment reporting to the NSLDS. Cause: The College?s policies and procedures did not include proper internal controls over compliance to ensure that this requirement was being met. Questioned costs: At the most, questionable costs would be interest accrued on the outstanding amounts of direct student loans which are insignificant, therefore there are no questioned costs. Recommendation: We recommend the College implement procedures to strictly comply with requirements of 34 CFR 682.610 and 34 CFR 685.309 as it relates to the student withdrawal status information reported to the NSLDS. We further recommend the College follow the guidance provided in the NSLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Response: In this case, this student was enrolled in an 8 week class that ran from 08/19/2019 to 10/15/2019 and a 16 week class that ran from 08/19/2019 to 12/13/2019. The student completed the first 8 week class and withdrew from the 16 week class on 10/13/2019. Therefore, the student?s enrollment went from half-time to less than half-time on 10/13/2019 and should have shown as withdrawn on 10/15/2019. Although the student withdrew from the 16 week class, they completed their first 8 week class, so our system coded them as ?eligible to enroll.? Therefore, they did not appear on our withdrawal reports. We have worked with our IT department and are now reviewing part of term withdrawals. Reports are checked at least once a week for students who withdraw during a semester and have completed all other classes showing they are no longer attending any courses. We then review and code them appropriately in our system and have checks in place when we submit students through the National Student Clearinghouse (NSC) and NSLDS. We have reviewed all students in the academic year 2019-2020 and have made all appropriate corrections with NSC and NSLDS.

2020-002 - Special Test and Provisions ? Disbursements to or on Behalf of Students Criteria: The U.S. Department of Education requires the College to properly handle post-withdrawal disbursements. If the amount of Title IV funds earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement. Post-withdrawal disbursement funds should be disbursed no later than 45 days after the date the College should have determined the student withdrew from all courses in accordance with 34 CFR 668.22 and 34 CFR 668.164. Condition: The College did not disburse a post-withdrawal disbursement of Title IV funds within the prescribed timeframe. Context: A sample of 25 students revealed that one student had completed coursework to merit a post-withdrawal disbursement. The disbursement was made 149 days after the date of determination. Effect: Title IV post-withdrawal funds were not disbursed in a timely manner. Cause: The College did not have specific procedures in place to comply with the timely disbursement of post-withdrawal funds. Records indicate that the College did identify and prepare the calculation timely, however, the disbursement occurred outside of the required timeframe. Questioned Costs: None. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668 as it relates to the return of Title IV funds and post-withdrawal disbursement of Title IV funds time requirements. Response: In this case, the student withdrew on 4/16/2020, during the COVID-19 pandemic. Campus was closed and the Department of Education had not released guidance on how to proceed with R2T4s. Initial guidance from the Department of Education suggested to wait to process R2T4s as students would not be held responsible for withdrawals due to COVID-19. The former employee, whose responsibility was to calculate R2T4s had done a calculation on this student on 5/6/2020 and determined they were owed a post-withdrawal disbursement. It was discussed that employee should pay post-withdrawal disbursements but not remove aid from student?s accounts until further guidance was given by the Department. The employee abruptly quit right after the calculation was performed. It was not discovered until recently that this student was not paid their post-withdrawal disbursement. Once realized, we have reviewed all of the former employee?s calculations during that timeframe and paid the student the post-withdrawal amount due. This payment was sent out to COD on 10/2/2020. A screen shot of the COD website was provided to show when the initial calculation was made and when payment was given to the student. Payments for post-withdrawals are now reviewed and noted as paid on every scheduled disbursement date throughout the semester.

2019-001 Special Test and Provisions ? Enrollment Reporting Criteria: The U.S. Department of Education requires the College to update changes in student enrollment status, report the date the enrollment status was effective, and submit changes electronically with the National Student Loan Data System (NSLDS) website in accordance with 34 CFR 682.610 and 34 CFR 685.309. Condition: The College did not have procedures in place to ensure change in enrollment information was accurately being reported to the Department of Education. Context: A sample of 40 students revealed that different effective dates were reported to NSLDS than what College records reflected for 2 students. Effect: The College was not in compliance with enrollment reporting to the NSLDS. Cause: The College?s policies and procedures did not include proper internal controls over compliance to ensure that this requirement was being met. Questioned costs: At the most, questionable costs would be interest accrued on the outstanding amounts of direct student loans which are insignificant, therefore there are no questioned costs. Recommendation: We recommend the College implement procedures to strictly comply with requirements of 34 CFR 685.309 and 34 CFR 682.610 as it relates to the student enrollment status date information reported to the NSLDS. We further recommend the College follow the guidance provided in the NSLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Response: It was found that the last enrollment report for the Fall term sent to the National Clearinghouse was sent in December. Because grades are not finalized until three days after the last day of the term, Return of Title IV Funds (R2T4) calculations with all F or F/W status were not completed until January. Therefore, the last date of academic related activity was not updated accordingly. Because enrollment reporting is sent through our Registrar?s office and R2T4 calculations are completed in the Financial Aid office, we did not recognize the timing was inaccurate for enrollment reporting. We have corrected both individuals directly on the National Student Loan Data System (NSLDS). We are also working with our IT Department, Registrar, the National Clearinghouse and NSLDS to send a corrected file to update all students affected for the 18-19 school year. Moving forward, we are coordinating with the Registrar?s office to schedule dates for reporting enrollment so that they include our last R2T4 calculations for the term.

2019-002 Special Test and Provisions ? Disbursements to or on Behalf of Students Criteria: The U.S. Department of Education requires the College to notify students, or parents, of their right to cancel all or a portion of the loan disbursements in writing, no earlier than 30 days before or 30 days after crediting the student?s account at the College. Condition: The College did not have proper policies and procedures in place to verify students, or parents, were notified of their right to cancel within the required time frame. Context: A sample of 40 students revealed that nine students were not notified of their right to cancel Federal Direct Loans within the required time frame during the Spring 2019 semester?s first loan disbursement. Effect: The College was not in compliance with notifying the student, or parent, of their right to cancel with Federal Direct Loan disbursements. Cause: There was an input error that caused the first disbursement of Federal Direct Student Loan funds in the Spring 2019 semester to register as the 2019-2020 academic year. This caused the failure of several students not receiving notification of the right to cancel all or a portion of the loan disbursements in the required timeframe. Questioned costs: None. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668 as it relates to notifying students, or parents, and their right to cancel loan disbursements within the required timeframe. Response: After extensive research, it was discovered the system was looking correctly at students with a loan disbursement on 1/28/19. Due to a setup error, in a shared Banner form, across multiple departments, the process pulled an incorrect aid year (FY19-20 instead of FY18-19). When the email was generated, the process pulled only students who had a FY19-20 FAFSA on file. This error was identified and corrected in February, however, we did not realize this affected our loan letter emails. The College disburses federal loans to individual students in two separate payments within a semester, half in the beginning of the semester and half mid-semester. Although students did not receive a disclosure email at their first disbursement, they did receive a disclosure email at their second disbursement. The College has eight scheduled disbursements each semester. The error occurred on the first disbursement dated 1/28/19. The error was found and corrected in our system before the other disbursements for the semester occurred. There is now verification that the disclosure statements were sent and are now accurate in our system. Going forward, an error report via email is sent daily that shows if a loan was paid and no email was sent. We will then be able to address the error more timely thus avoiding the 30 day late notification.

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