Community College District of Central Southwest Missouri - Ozarks Technical Community College

2022-001 Special Test and Provisions - Return of Title IV Funds. 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. Condition: The College did not return unearned Title IV funds within the prescribed timeframe. Context: A sample of 25 R2T4 calculations revealed that nine students had Title IV funds returned later than the allowable timeframe. All funds were returned in the proper order and amount. Effect: Title IV funds were not returned in a timely manner. Cause: The College did not 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. Questioned Costs: The questioned costs would be insignificant due to the funds being returned in the proper order and amount. Repeat Finding: This is a repeat finding from the previous audit, 2021-002. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. Response: The College has well defined policies and procedures that outline attendance requirements (policy 2.61) and the process for administratively withdrawing students (policy 2.64) who have met the criterion for 14 consecutive calendar days of non-attendance. Instructors are required to adhere to College policies. The College has systems defined for producing a report of students who have officially and unofficially withdrawn and procedures for reviewing if a return of funds calculation is required. However, changes presented to schools with the Return of Funds regulations in early summer were difficult to understand and to incorporate pertaining to the new module language. Though we provided consistent methodology in line with our interpretations of the rules, we continued to evaluate our interpretation through various instruction from FSA handbook and webinars, NASFAA University Classes, NASFAA webinars and state association colleagues. Due to our hesitation to calculate a return of funds incorrectly, we had instances where the 45 days was exceeded. With regards to our calculations and reviews, we erred on the side of taking the needed time to confirm we had the correct calculation for the student versus calculating the percentage incorrectly and causing an increased balance for the student. We followed up with the Kansas City Department of Education Office and received final clarification our understanding of the new rules

2021-001 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 change in enrollment information was accurately reported to the Department of Education within the required timeframe. Context: A sample of 40 students revealed the enrollment status level change between full time and three quarters time was not properly reported for 2 students. Effect: The College was not in compliance with the proper 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 Cost: None. 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 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. Response: The Registrar attended the NSC webinar ?Submitting Enrollment and Degree Files? in January 2021 and confirmed the College appears to be following best-practice in the submission of all enrollment reports. The College has submitted a support case with National Student Clearinghouse to discuss possible reasons why the timing of enrollment status reports were delayed and/or reported with a different change in status date. The college strives to ensure procedures are in place for timely filings and will continue to monitor this issue through resolution.

2021-002 Special Test and Provisions ? Return of Title IV Funds 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. Condition: The College did not return unearned Title IV funds within the prescribed timeframe. Context: A sample of 25 R2T4 calculations revealed that two students had Title IV funds returned later than the allowable timeframe. All funds were returned in the proper order and amount. Effect: Title IV funds were not returned in a timely manner. Cause: The College did not 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. Questioned Costs: The questioned costs would be insignificant due to the funds being returned in the proper order and amount. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. Response: The College has well defined policies and procedures that outline attendance requirements (policy 2.61) and the process for administratively withdrawing students (policy 2.64) who have met the criterion for 14 consecutive calendar days of non-attendance. Instructors are required to adhere to the College policies. As referenced in 34 CFR 668.173(c)(2), ?The Secretary does not consider an institution to be out of compliance with the reserve standard under 668.173(a)(3) if the institution is cited in any audit or review report because it did not return unearned funds in a timely manner for one or two students, or for less than 5% of the students in the sample referred to in paragraph (c)(1)(i) of this section?. This audit indicates that only two students were found outside of the allowable timeframe in the sample. The College understands the necessity to reduce any issues with return of funds and will continue to work with instructors on a regular basis to adhere to the policies and procedures established to stay in compliance with these regulations.

2019-001 Special Tests and Provisions: Return of Title IV Funds Criteria: The U.S. Department of Education requires the College to return Title IV funds within 45 days after the date the College determined the student withdrew in accordance with 34 CFR 668.173. Condition: The College did not return unearned Title IV funds within the prescribed timelines. Context: A sample of 25 students required to have R2T4?s performed revealed that three students had Title IV funds returned later than 45 days after the date of determination. The first student?s Title IV funds were returned 79 days after the date of determination which was 93 days after the student?s last date of attendance. The second student?s Title IV funds were returned 53 days after the date of determination which was 67 days after the student?s last date of attendance. The third student?s Title IV funds were returned 60 days after the date of determination which was 74 days after the student?s last date of attendance. Effect: Title IV funds were not returned in a timely manner. Cause: The College did not have specific procedures in place to ensure and verify timely reporting of withdrawals by instructors which in turn did not provide enough time for the College to identify, prepare, and return funds in a timely manner. Questioned costs: At the most, questionable costs would be interest accrued which are insignificant, therefore there are no questioned costs relating to the issues noted with Title IV funds returned later than the required 45 days after the date of determination. Repeat Finding: This is a repeat finding from the previous audit, 2018-001. Recommendation: We recommend the College implement procedures in order to strictly comply with the requirements of 34 CFR 668.173 as it relates to the time requirements. Response: The College, while working with several departments such as Online, Academics, Financial Aid and Information Technology, developed additional reports during this year, which are now provided to academic leadership to assist in identifying potential issues with non-reporting or possible late reporting of last dates of attendance by instructors. Specific procedures were put into place to communicate and to follow up with completion of the last dates of attendance and administration of the Administrative Withdraw Policy and Procedures. Various attendance reporting software solutions continue to be reviewed for possible implementation and best fit with the college?s processes and student population.

2019-002 Special Tests 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 change in enrollment information was accurately being reported to the Department of Education within the required timeframe. Context: A sample of 40 students revealed that enrollment status was not reported within the required timeframe for 10 students and different effective dates were reported to NSLDS than what College records reflected for 13 students. In addition there were 2 students who did not have the proper enrollment status reported to NSLDS. Effect: The College was not in compliance with enrollment reporting to the NSLDS and the College was not in compliance with the timely reporting requirements for NSLDS reporting. Cause: The College?s policies and procedures did not include proper internal controls over compliance to ensure that these requirements were 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 and 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. Response: 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 and within a designated timeline of reporting. Having multiple start times (modules) within a term, has created its own challenges as we identify additional drop and add dates to report changes to enrollment. With multiple end dates, we also have additional graduation dates. Additional review of the process has been requested; therefore, our internal auditor is preparing to assist in a broader review of the process as a whole.

2019-003 Special Tests and Provisions: Disbursements to or on Behalf of Students Criteria: The U.S. Department of Education requires the College to return any Title IV funds, except Federal Work Study funds, that it attempts to disburse directly to a student which are returned or rejected no later than 240 days from the initial attempt to disburse the funds. Condition: The College has procedures in place to return any Title IV funds returned or rejected within the required time frame, but these procedures were not followed due to an ongoing federal program review. Context: Discussion with College personnel noted these returned or rejected funds were still being monitored, but were not being returned to the U.S. Department of Education until the Final Federal Program Review was completed. Cause: The College was undergoing a federal program review and had been instructed to halt all return of funds to the U.S. Department of Education until the federal program review was completed. Questioned costs: None as all funds were being monitored and were released back to the U.S. Department of Education upon completion of the federal program review. Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668.164(1) as it relates to the return of any Title IV funds returned or rejected within the required 240 days after the date of the initial attempt to disburse funds to the student. Response: The College has procedures in place to align with the 240 day requirement to return unclaimed or rejected Title IV funds. Procedures outline both Student Account Services and Financial Aid responsibilities.

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