Columbia CollegeHigher Education

2024-001 – Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Department of Education, SFA Cluster; Special Tests and Provisions Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: From a population of 208 students that officially or unofficially withdrew from a payment period, we tested 22 and noted that ten students required refund calculations. From these calculations we noted the following: 1) Thanksgiving break of five days was deducted incorrectly from total days in three calculations. 2) Spring break of nine days was deducted incorrectly as five days in one calculation. Cause: The College’s spring break was scheduled for the period February 26, 2024 through March 1, 2024, a total break of nine days for traditional students with no online classes. One traditional student with no online classes was tested and the break was incorrectly deducted as five days instead of nine. Three on-line students were tested, and a break of five days was deducted from total days, however, online classes were in progress during spring break and no break days should have been deducted. Effect: The refund was incorrect for four students that had refund calculations prepared. Repeat Finding from a Prior Year: Repeat of 2023-004. Recommendation: We recommend the College put procedures in place for accurate preparation and calculation of Title IV refunds. Management Response: We concur with this finding. The Office of Financial Aid conducted an internal review of all Return of Title IV (R2T4) calculations for the 2023-2024 academic year. Two students within the audit sample had been corrected prior to the audit; however, their disbursements were not updated in the Common Origination and Disbursement (COD) system at the time of the request. To prevent future discrepancies, we have collaborated with PowerFAIDS to ensure that the appropriate number of days associated with Thanksgiving and Spring Break are accurately assigned to students. Additionally, each financial aid counselor will complete the R2T4 calculation within three days of receiving a withdrawal notification email. Upon completion, the calculation will undergo a review by the Associate and/or Senior Director of Financial Aid to verify accuracy.

2024-002 – Reporting Student Withdrawal Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Department of Education, SFA Cluster; Special Tests and Provisions Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 208 students that withdrew officially or unofficially during the fiscal year, we tested 22 and noted that withdrawal dates were submitted untimely for all 22 students and the incorrect date was reported for six students. Cause: NSLDS Enrollment Reporting was submitted more than 60 days after the date of determination for all 22 students and the incorrect withdrawal date was reported for six students. Effect: The Department of Education was unaware of the student withdrawals; thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Repeat Finding from Prior Year: Repeat of 2023-005. Recommendation: We recommend that a review process be put in place to ensure complete and accurate NSLDS reporting of student withdrawal dates. Management Response: We concur with this finding. The Office of the Registrar reports the withdrawal date via Clearing House. However, the withdrawal date is overridden by any subsequent enrollment updates. Moving forward, the Office of Financial Aid will ensure that withdrawal dates for R2T4 calculations are accurately reported. The updated enrollment information will be saved in the student’s electronic file to maintain proper documentation and compliance.

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Department of Education, SFA Cluster Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the school’s Campus Based Program funding for the upcoming award year as well as report Campus‑Based Program expenditures for the prior award year. The College is required to submit a Fiscal Operations Report plus other information required; the information must be accurate and shall be submitted on the form at the time specified, 34 CFR 674.19(d)(2). Condition: During our review of the College’s FISAP it was determined that tuition and fee revenue was overstated and Pell amount reported was understated. Cause: Tuition and fee revenue reported on the FISAP included deferred tuition and fees that that were not recognized until the subsequent year. Pell was understated due to preparation of the FISAP before a reconciliation was completed. Effect: Incorrect reporting of information may cause federal funding for the College to be over-awarded or under-awarded in subsequent years. In addition, failure to accurately report the College’s FISAP may jeopardize future federal funding. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College improve procedures to ensure accurate reporting. Management Response: We concur with this finding. Staff made a “change request” to the U.S. Department of Education (USDOE) to adjust the FISAP. Once the “change request” was approved by the USDOE, we edited the FISAP report to appropriately reflect the audited numbers. It is important to note that the FISAP is due by September 30th, and the USDOE allows institutions until December 15th to adjust the figures. Our audited financial statements are due no later than September 30th, which normally allows time to ensure that the figures on the FISAP are reconciled to the ones on the audited financial statements. Nevertheless, if the audited statements are not completed by the September 30th deadline, we will make sure that any adjusting entries to the FISAP are made by the final date of December 15th.

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Cause: Administrative oversight. Effect: Not processing awards timely results in inaccurate student accounts and may result in students being awarded Title IV Direct Loans in excess of the cumulative limitations in a subsequent period of enrollment. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College implement procedures to ensure that all Title IV Direct Loans accepted by students are disbursed timely. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester.

2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Department of Education, SFA Cluster Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 140 students that received all failing grades in a term, we tested fourteen students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Cause: The College considers students that receive a grade of F to have attended the entire period, however, no written attendance policy exists to this effect and no documentation could be provided to support the last day of the student’s attendance at an academically related subject. Effect: Since there is no formal written policy requiring instructors to utilize different grades for students that fail a class after attending the entire term and for students that failed to attend through the end of the term, it is unclear whether the student attended through the end of the period. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College implement a policy in which instructors are required to retain documentation of a student’s last date of attendance and the grades assigned to a student failing a class indicate whether the student attended through the end of the period or stopped attending prior to the end of the period. In addition, we recommend documentation of a student’s last date of attendance at an academically related class be maintained. Management Response: We concur with this finding. With enhancements to the Jenzabar ONE system, the institution has implemented a new process that requires professors to enter the Last Day of attendance (LDA) for any student who earned an F grade. Going forward, the Registrar will present a report to the Office of Financial Aid two days after final grades post for the semester. The report will have the students who have all Fs with their LDS listed for each class.

2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Department of Education Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. If a student withdrawals by providing notification to designated officials, the withdrawal date is the date notification was provided. Institutional charges used in the refund calculation are the charges that were initially assessed the student for the entire payment period. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that four of the seven had refund calculations prepared. From these calculations we noted the following: 1. Breaks of five or more consecutive days were not deducted from total days in all refunds. 2. The date of the college’s determination was used as the withdrawal date for three of the four students. 3. Institutional charges for the period used in the refund calculation included tuition and fee credits processed due to the withdrawal for two of the four students. Cause: The College’s Thanksgiving break of five consecutive days and Spring break of nine consecutive days were not deducted from the total days in the semester for any refund calculation during the fiscal year. Three of the student’s refund calculations were prepared using the college’s date of determination instead of the date of the student’s withdrawal. The college processed a credit for tuition and fees when the student withdrew, and this credit reduced institutional charges in the refund calculation for two of the four students. Effect: The refund was incorrect for all four students that had refund calculations prepared. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College put procedures in place for accurate preparation and calculation of Title IV refunds. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training on R2T4 processing along with other regulations. System updates are performed during the Fall semester for the next year. During this update, R2T4 parameters are set and monitored to ensure accuracy. In addition, the R2T4 calculations now include adjustments made to the students’ account at the time of withdrawal.

2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Department of Education, SFA Cluster Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. The change in status was not reported to NSLDS for one student and the last date of the semester was reported instead of the withdrawal date for four students. Cause: Incorrect date or no date was reported in NSLDS Enrollment Reporting. Effect: The Department of Education was unaware of the student’s withdrawal; thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Repeat Finding from Prior Year: No. Recommendation: We recommend that a review process be put in place to ensure complete and accurate NSLDS reporting of student withdrawal dates. Management Response: The Registrar’s Office maintains the institution’s enrollment records. During the fall of 2023, the enrollment reporting process was moved to the Registrar’s Office to ensure the accuracy of reporting.

2023-006 Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. Four of the students refund calculations were not completed in a timely fashion and two students that completed a withdrawal form did not have a refund calculations prepared. The College did not return Title IV funds for the two students that should have had refund calculations and the College did not return Title IV funds within 45 days after the date of determination of the student’s withdrawal for the four students that had refund calculations prepared. Cause: The two students that did not have refund calculations prepared withdrew electronically, however the withdrawal was not communicated to the Financial Aid Department in order to have a refund processed. Due to this, the students were considered by the College to have attended the entire semester and received failing grades for all classes. The refund calculations that were prepared for four students were prepared more than 45 days after the date of determination, thus, funds were returned more than 45 days after the date of determination of the student’s withdrawal date. Effect: The two students that withdrew but were not processed received failing grades in their classes instead of being withdrawn from their classes and no refund calculation was prepared. The four students that had refund calculations prepared were not prepared timely, resulting in Title IV funds not being returned timely. Repeat Finding from a Prior Year: No. Recommendation: We recommend the College put a process in place to ensure student withdrawal requests are processed properly and timely, and Title IV funds are returned timely. Management Response: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the communication list for withdrawals was updated with the Director of Financial Aid’s information to ensure the financial aid office receives all withdrawal information in a timely manner.

2023-007 Exit Counseling (Significant Deficiency) Department of Education, SFA Cluster Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower’s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: During our testing, we noted eight instances, in a sample of nine students requiring exit counseling, in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates. Repeat Finding from a Prior Year: Yes. Recommendation: We recommend the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this counseling should be retained by the College. Management Response: We concur with this finding. Currently, students receive a withdrawal notification that provides them with a link to complete their exit counseling. Moving forward and during the completion of the withdrawal, the students will be presented with an exit counseling digital page. On this page, withdrawal information will be provided to the student along with the deadline to complete the exit counseling. Students will also certify that they have received and understood the information. Once the withdrawal form is completed, students will get a follow up email that will also direct them to the exit counseling at www.studentaid.gov and inform them of the 30-day deadline.

Finding 2022-001 Entrance Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must provide students with entrance counseling to explain the loan obligation, including the borrower?s rights and responsibilities, prior to a loan disbursement to a first-time Federal Direct Loan borrower. The required elements of entrance counseling are the reinforcement of repayment, the consequences of a default, that payment is required regardless of educational outcome and employability, and to explain the use of the promissory note. The counseling must be conducted in person, by audiovisual presentation, or by interactive electronic means. Context: During our testing, we noted 2 instances in a sample of 61 students in which evidence of entrance counseling could not be provided by the College. Cause: Administrative oversight. The College did not properly monitor the disbursement of funds with the students who had completed the entrance interview. These students may not have been informed of their rights and responsibilities under the Federal Direct Loan Program. Recommendation: The staff at Columbia College should ensure that all students participating in the Federal Direct Loan Program receive the initial loan counseling prior to the disbursement of funds. This should be evidenced with a copy of the entrance interview in the students? files. Views of Responsible Officials and Planned Corrective Actions: The Financial Aid Officers will check Common Origination Disbursement (COD) to ensure that the student has a valid entrance counseling. The counselor will provide a comment that the entrance counseling has been reviewed in the comment section of our Financial Aid system.

Finding 2022-002 Exit Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower?s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Context: During our testing, we noted 4 instances in a sample of 61 students in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates. Recommendation: We recommend that the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this counseling should be retained by the College. Views of Responsible Officials and Planned Corrective Actions: The Director of Financial Aid will ensure that all students who withdraw or drop below half-time school-hours will complete exit counseling. Enrollment reports will be reviewed, and the appropriate action will be taken. Students who withdraw will complete the exit counseling at the time of withdrawal. Students who withdraw with notification will be conducted by phone, email, and a certified letter with the steps to complete the exit counseling.

Finding 2020-002 General Conditions and Limitation of Employment Federal Work-Study Program ? CFDA No. 84.033 Criteria and Condition: In general, students are not permitted to work in Federal Work-Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Context: We noted that 4 of the 5 Federal Work-Study students tested worked during scheduled class time and the College had no documentation to support whether or not any of the exceptions above were applicable. Cause: Administrative oversight. Effect: Students may have worked during scheduled class time in violation of federal regulations. Recommendation: We recommend that the College implement procedures to ensure that Federal Work-Study students do not work during scheduled class times. In the event a student does work during scheduled class time subject to one of the exceptions noted above, the College should maintain documentation in the student?s file of such qualifying exception. Views of Responsible Officials and Planned Corrective Actions: The Office of Financial Aid will work with the student employment coordinator to create FWS separate workshops for supervisors and students. The workshops will be mandatory and will discuss the rules and responsibilities of each party as it relates to the Federal Work-Study Program. One of the highlighted rules will be that students are not allowed to work during scheduled class time and the institution will adopt the policy that students are not allowed to work at all during class time even if the student has a documented class cancellation.

Finding 2019-004 Exit Counseling Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Context: During our testing, we noted 2 instances in a sample of 71 students in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Cause: Administrative oversight. Effect: Not providing the necessary information or performing exit counseling may result in penalties or sanctions from the Department of Education in addition to higher default rates.Recommendation: We recommend that the College implement procedures to ensure that borrowers who cease enrollment be notified of the need to complete exit counseling. Evidence of this exit counseling should be retained by the College. Views of Responsible Officials and Planned Corrective Actions: The Office of Financial Aid has created a process with the Registrar that will identify students that are scheduled to graduate, students that drop below half-time enrollment status, and students who do not attend the institution the following semester. This collaboration with the Registrar will allow the Office of Financial aid to identify the students that need to have exit counseling information sent to them. Furthermore, for students who withdraw during the semester, the Office of Financial Aid has implemented a process that will send exit counseling information to the student at the time of the R2T4 calculation.

Finding 2019-005 Return of Title IV Funds Federal Direct Loan Program ? CFDA No. 84.268 Federal Pell Grant Program ? CFDA No. 84.063 Criteria and Condition: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his/her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs. The return must occur within 45 days of the institution becoming aware that the student had withdrawn. Context: In a sample of 80 students, returns should have been made for 4 students, but no Title IV funds were returned. For another student, the return of Title IV funds took 57 days from the date of withdrawal. Questioned Costs: See Schedule of Finding and Questioned Costs for chart/table Cause: Administrative oversight. Effect: The students received Title IV aid in excess of their financial need and returns of unearned funds were not made within 45 days after the College determined that the students withdrew. Recommendation: The College should review its system for tracking student withdrawals and calculating unearned Title IV funds to ensure that such unearned funds are returned to the Department of Education in a timely manner. Views of Responsible Officials and Planned Corrective Actions: It has been historical practice at the institution that the tuition accounts office processed R2T4 calculations. Once the calculation was processed it would be submitted to the Office of Financial Aid for the return of aid to be processed. Once complete, tuition accounts would then return the money. Starting in the 2019-2020 year, the Office of Financial Aid has taken over responsibility for the entire R2T4 process, with the exception of the actual return of funds which is processed by the Controller. The Senior Director of Financial Aid has implemented controls that will capture all students that have withdrawn from the institution during a term and that all calculations are processed in a timely manner.

Finding 2019-006 Borrower Data Transmission and Reconciliation Federal Direct Loan Program ? CFDA No. 84.268 Criteria and Condition: Institutions must report all loan disbursements and submit required records to the Department of Education?s Common Origination and Disbursement (COD) web site within 15 days of disbursement. Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Context: The College could not provide documentation to support that monthly reconciliations were being performed. The auditor obtained 3 of the monthly SAS data files and reconciled to the College?s financial records with only immaterial differences being noted. Questioned Costs: N/A Cause: Unknown Effect: It was not possible to determine if the College performed the required monthly reconciliations. Recommendation: The College should develop procedures to ensure that the monthly SAS data files are reconciled to the College?s financial records on a monthly basis and that evidence of such reconciliations are retained to support that the College is in compliance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The Senior Director of Financial Aid has worked closely with the Controller to implement a reconciliation process that is conducted monthly. This process is to ensure that monthly drawdowns from G5 are reconciled with what the Office of Financial Aid had disbursed for the same month. The Office of Financial Aid will utilize the SAS Cash Detail and SAS Disbursement detail reports along with reports out the student information system to perform proper monthly reconciliation.

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