Junior College District of East Central, MissouriHigher Education

2025-001 Special Test and Provisions – Return of Title IV Funds U.S. Department of Education Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063 & 84.268 Award Year: 2024-2025 Significant Deficiency and Compliance Criteria: Under 34 CFR §668.22, the College is required to return Title IV funds in accordance with federal regulations governing the Return of Title IV (R2T4) calculation. This calculation determines the amount of unearned aid by subtracting the assistance earned by the student from the total aid disbursed. The percentage of earned and unearned funds is based on the student’s attendance within the College’s defined payment period. Condition: In a sample of 25 R2T4 calculations, it was determined that College entered the academic calendar dates incorrectly in the calculation, which resulted in two calculation errors. Cause: The College had a change to the academic calendar that did not get updated in the financial aid software. Effect: All students with a Spring R2T4 that did not complete 60% or more of the semester potentially have an incorrect R2T4 calculation of, up to, a five day difference. Questioned Costs: All questioned costs are below the known and likely questioned costs reporting threshold. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Response: The College conducted a comprehensive review of all student accounts potentially impacted by the incorrect academic calendar dates and identified 52 students whose Return of Title IV (R2T4) calculations required review. As a result of this review, the Financial Aid Office determined that 41 students required a return of Title IV funds to the U.S. Department of Education.  The total amount of funding returned was $12,590. The Financial Aid Office corrected the R2T4 calculations, updated the academic calendar dates in the financial aid system, and processed the required returns of Title IV funds. To prevent recurrence, the College has implemented internal procedures to ensure academic calendar dates are reviewed and verified in the financial aid system before performing R2T4 calculations for each award year.

Compliance Finding and Significant Deficiency ? 2021-001 U.S. Department of Education Student Financial Assistance Cluster Assistance Listing Number(s): 84.007, 84.033, 84.063 and 84.268 Award year: 2020-2021 2021-001 Special Tests and Provisions: Enrollment Reporting Condition: The College did not have procedures in place to ensure change in enrollment information was accurately reported to the Department of Education within the required timeframe. 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. Cause: The College Procedures did not include proper internal controls over compliance to ensure that these requirements were being met. Effect: The College was not in compliance with proper effective date reporting requirements for NSLDS reporting. Context: A sample of 40 students revealed that the enrollment status effective date was reported incorrectly for 3 students. 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. Repeat Finding: No. Prior year finding was related to late reporting of enrollment status changes. 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 reporting requirements. 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. College Response: East Central College relies on the accuracy of faculty reporting to submit subsequent enrollment changes to the Clearinghouse and ultimately the National Student Loan Database. Per College policy, Instructors submit which students to drop and when that is to happen. The College has several departments working together to review the enrollment reporting processes: registrar, information technology, and financial aid. These offices work together alongside the Clearinghouse to work through possible errors in reporting within a designated timeline of reporting. Additional review of the process continues regularly.

Compliance Finding and Significant Deficiency ? 2021-002 U.S. Department of Education Student Financial Assistance Cluster Assistance Listing Number(s): 84.007, 84.033, 84.063 and 84.268 Award year: 2020-2021 2021-002 Special Tests and Provisions: Return of Title IV Funds Condition: The College did not return unearned Title IV funds within the prescribed timeframe. Criteria: In accordance with 34 CFR 668.173(b), the College must return Title IV funds within 45 days after the date the College determined the student withdrew. Additionally, the College is considered an attendance taking school, therefore, they must make the determination that the student withdrew no later than 14 days after the student?s last date of attendance as determined by the College from its attendance records. Cause: The College did have specific procedures in place to ensure timely reporting of withdraws by instructors, which in turn, did not provide enough time for the College to identify, prepare, and return funds within the required timeframe. Effect: Title IV funds were not returned in a timely manner. Context: A sample of 25 R2T4 calculations revealed that two students had Title IV funds returned later than the allowable timeframe. One student?s Title IV funds were returned 98 days after the date of determination which was 124 days after the student?s last date of attendance. Another student?s Title IV funds were returned 20 days after the date of determination which was 93 days after the student?s last date of attendance. All funds were returned in the proper amount. Questioned Costs: The questioned costs would be insignificant due to the funds being returned in the proper order and amount. Repeat Finding: No. Recommendation: We recommend the College implement procedures to strictly comply with requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. College Response: The College will investigate and update the existing procedures in subsequent semesters to ensure accurate return of funds. This will include many departments working collaboratively including, but not limited to, the registrar, information technology, and financial aid. The departments will continue to review the procedures regularly.

Compliance Finding and Significant Deficiency ? 2021-003 U.S. Department of Education Education Stabilization Fund Assistance Listing Number(s): 84.425 Award year: 2020-2021 2021-003 Reporting Condition: The College did not have procedures in place to ensure proper special reporting of the HEERF funds. Criteria: The U.S. Department of Education requires the College to report quarterly the aggregate amounts of HEERF Institutional funds spent during that quarter. Additionally, the College must report quarterly certain information regarding the Student Aid portion including the total amount of aid distributed, the total number of students at the College eligible for a distribution, total number of students who have received a distribution, and the method used to determine which students were eligible. Cause: The College Procedures did not include proper internal controls over compliance to ensure that these reporting requirements were being met. Effect: The College was not in compliance with accurate quarterly reporting of Institutional funds spent. Additionally, the College was not in compliance with quarterly Student Aid portion reporting by missing key reporting items noted above in the criteria section. Context: Each quarterly report was reviewed on the College?s website. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend the College implement procedures to strictly comply with the requirements set forth under the CARES(a)(1) and CRRSAA programs and further explained through subsequent HEERF FAQs provided by the Department of Education regarding required quarterly reporting on the College?s website. College Response: The College has subsequently updated all the required reporting elements on the website and will continue to review ongoing guidance from the Department of Education.

Compliance Findings and Significant Deficiency ? 2020-001 U.S. Department of Education Student Financial Assistance Cluster CFDA Nos. 84.007, 84.033, 84.063 and 84.268 Award year: 2019-2020 2020-001 Special Tests and Provisions: Enrollment Reporting Condition: The College did not have procedures in place to ensure change in enrollment information was accurately reported to the Department of Education within the required timeframe. 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. Cause: The College Procedures did not include proper internal controls over compliance to ensure that these requirements were being met. Effect: The College was not in compliance with timely reporting requirements for NSLDS reporting. Context: A sample of 40 students revealed that enrollment status was not reported within the required timeframe for 2 students. 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. Repeat Finding: No. 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 timely reporting requirements. 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. College Response: East Central College relies on the timing and accuracy of faculty reporting to submit subsequent enrollment changes to the Clearinghouse and ultimately the National Student Loan Database. Per College policy, Instructors submit which students to drop and when that is to happen. The college has several departments working together to review the enrollment reporting processes: Registrar, Information Technology, and Financial Aid. These offices work together alongside the Clearinghouse to work through possible errors in reporting within a designated timeline of reporting. Additional review of the process continues regularly.

U.S. Department of Education Student Financial Assistance Cluster CFDA Nos. 84.007, 84.033, 84.063 and 84.268 Award year: 2018-2019 2019-001 Eligibility ? Calculation of Benefits Condition: The College did not award Direct Subsidized Loans when all eligibility requirements were met. Criteria: The College is required to calculate and package awards based on financial need. Specifically, the College is required to follow program requirements of Direct Subsidized Loans in accordance with 34 CFR sections 685.200 and 301. For an undergraduate student who has not yet successfully completed the first year of study, a student is eligible for up to $3,500 in Direct Subsidized Loans for a program of study at least an academic year in length assuming all other eligibility requirements have been met. Cause: The College did not have specific procedures in place to properly package and award Direct Subsidized and Unsubsidized Loans. Effect: Direct Unsubsidized Loans were awarded when Direct Subsidized Loans should have been awarded. The recipient was not allowed the benefit of subsidized interest on the loan. Context: A sample of 40 students revealed that one student received their full Direct Loan award as an Unsubsidized Loan. The student met all eligibility requirements to receive $2,250 of the award as a Subsidized Loan. A non-statistical sampling methodology was used to select the sample. Questioned Costs: The known questioned cost was the $2,250 awarded as an Unsubsidized Loan that should have been awarded as a Subsidized Loan. This amount is below the threshold of reporting for known questioned costs. Repeat Finding: No. Recommendation: We recommend the College implement procedures in order to strictly comply with the requirements of 34 CFR 682.200 and 301 as it relates to awarding Direct Loans. College Response: We concur. The College did properly calculate benefits for the student, however, during processing of the award, errors were made switching the approved subsidized payment to unsubsidized. Procedures are now in place to review the initial awarding information against the disbursement information to ensure all awards are processed correctly. Further, the College is automating the awarding process to help eliminate human error.

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