CLINTON COLLEGEHigher Education

Finding 2021-001 - FSEOG Condition The College disbursed six of the students FSEOG awards all in one payment period (semester), instead of disbursing one half of the total award in each semester. In the sample of students, three students enrolled for one semester only, but received the total annual award resulting in each of those students receiving $150 more that should have been allowed. A total of thirteen students received FSEOG awards in the sample of students selected for testing. Corrective Action Plan The institution does agree with the finding. Clinton College. To prevent this from becoming a repeat finding, the College is working with a third-party servicer, Global Financial which began assisting with the disbursements of Federal Supplemental Education Opportunity Grant. Global Financial does use a electronic system which ensures the proper disbursements of the FSEOG funds to be disbursed so that there will be no over awards of funds for one term Anticipated Completion Date: August 31, 2022 Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid

Finding 2021-002 ? General Provisions - FISAP Condition The College reported 167 undergraduate students in Section D, but the data from Campus Cafe indicates the there were 135 students. In Section E the tuition and fees were significantly understated. In Section F the distribution of eligible aid applicants enrolled in the tables did not agree with the underlying records. The total number of applicants appear correct, but some of the counts amoung the income ranges did not agree with the College's records. Corrective Action Plan The College does agree with the finding. The College is working with a third-party servicer, Global Financial. Global Financial will be monitoring and assisting with the FISAP reporting and calculations to ensure more accurate reporting and electronic processing for all program awards. Anticipated Completion Date: The next due date for the FISAP. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid

2020-006

Finding 2020-001 - ENROLLMENT REPORTING Condition The College uses a servicer to update the National Student Loan Data System (NSLDS). Testing revealed four students had a status of "No Record Found" and one student's record did not indicate that a degree had been awarded. The sample of students selected was 40, which is approximately 20% of the population. Corrective Action Plan The institution does agree with the finding. Clinton College has updated the Enrollment Reporting Policy and this updated policy was submitted in the program review to the US Department of Education. The College contracts with the National Student Clearinghouse (NSC) to complete the enrollment reporting requirements. The College confirms and reports the enrollment status of all students to the NSC. The NSC will use the data file provided by the College to complete the Enrollment Reporting file from the National Student Loan Data System. The financial aid office and registrar?s office will work closely to monitor both the National Clearinghouse records and any errors compared to the National Student Loan Data System to ensure that errors are resolved in a timely and efficient manner. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid Anticipated Completion Date: August 31, 2021

Finding 2020-002 - VERIFICATION OF APPLICANT'S INFORMATION Condition There were eight students with specific findings with respect to verifications. The data for three students did not agree to the tax documentation provided; there were no verification documents for one student; and four students required additional verification (V4 verification tracking flag) that was not performed. The sample of students selected was 40, which is approximately 20% of the population. Corrective Action Plan The institution does agree with the finding. Clinton College has created a verification policy which was included in the Program Review Report submitted to the US Department of Education. Each year, about 30% of students who submit a FAFSA are selected by the federal government for verification. Students who are selected for verification must submit to Clinton College copies of the information they used to file the Free Application for Federal Student Aid (FAFSA). This includes documentation of filing an income tax return and certain other financial documents. The institution has partnered with a third party servicer, Global Financial. The financial aid office will work closely with Global Financial to ensure that all required documents are submitted electronically and reviewed in a timely manner before the student is packaged and awarded. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid Anticipated Completion Date: August 31, 2021

Finding 2020-003 - SATISFACTORY ACADEMIC PROGRESS (SAP) Condition There were four students whose academic records indicated a different SAP status from the documentation in the students' files. Generally, the College's current SAP policy states that SAP is reviewed at the end of each semester, but documentation in the students' files indicated only one verification was performed. Corrective Action Plan The institution does agree with the finding. The financial aid office will create an evaluation form for each semester. The new SAP policy has been included in the Program Review Response to the US Department of Education. The updated policy includes that the Federal regulations require that educational institutions create, implement, and monitor compliance with a policy about the satisfactory academic progress (SAP) a student must make in order to be eligible for FSA funds. Students must meet BOTH the qualitative and quantitative standards each semester in order to receive financial aid for the next semester. The financial aid office has devised a new system to work closely with the Academics Department to monitor student?s progress throughout each semester. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid Anticipated Completion Date: August 31, 2021

Finding 2020-004 - EARLY DISBURSEMENTS Condition There were eleven students that received Pell and Direct Loan amounts prior to 10 days before the first day of class. The funds were credited to their accounts ranging from 18 to 30 days prior to the first day of class for the semester. The sample of students selected was 40, which is approximately 20% of the population. Corrective Action Plan The institution does agree with the finding. Clinton College has updated the policy to ensure the correct disbursement of Federal Direct Loans in the future. The updated policy has been included with the Program Review Report Response submitted to the US Department of Education. No funds will be disbursed prior to meeting a 10-day seat time requirement in each class for returning students. First year, first time students disbursements will be made after the student has been enrolled in the institution for 30 days. When a student receives a Direct Loan, the student will be contacted by the loan servicer (the student repays the Direct Loan to the loan servicer). The loan servicer will provide regular updates on the status of the Direct Loan, and any additional Direct Loans that a student receives. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid Anticipated Completion Date: August 31, 2021

Finding 2020-005 - DELAYED DISBURSEMENTS Condition There were nine first-time borrowers/students that received their loan funds prior to the 30 days required by law. There was a total of thirteen first-time borrowers in the sample selected. Corrective Action Plan The institution does agree with the finding. Clinton College has updated the policy to ensure the correct disbursement of Federal Direct Loans in the future. The updated policy has been included with the Program Review Report Response submitted to the US Department of Education. Clinton College's Financial Aid Office will adjust students awards throughout add/drop periods, or as deemed necessary to ensure accuracy before disbursement. The financial aid office will work closely on monitoring student?s completion of the Master Promissory Note and Entrance Counseling in a timely manner to ensure that there are no delayed disbursements. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid Anticipated Completion Date: August 31, 2021

Finding 2020-006 - FSEOG DISBURSEMENTS Condition The College disburses each student?s FSEOG award all in the first payment period (semester), instead of disbursing one half each semester. In the sample of students, two students did not return for the second semester resulting in each student receiving $150 more that should have been allowed. A total of five students received FSEOG award in the sample of students selected for testing. Corrective Action Plan The institution does agree with the finding. Clinton College has created a Federal Supplemental Education Opportunity Grant policy. This new policy has been included in the Program Review Report Response to the US Department of Education. To determine if a student is eligible, the U.S. Department of Education uses a standard formula to evaluate the information reported on the Free Application of Federal Student Aid (FAFSA). The formula produces an Expected Family Contribution (EFC) number. A portion of the award will be provided to the student in each payment period during the academic year in equal amounts. The Office of Financial Aid will award a student up to $150 per semester, depending on the student?s financial need. Name of Contact Person Responsible for Corrective Action: Pamela White, Director of Financial Aid Anticipated Completion Date: August 31, 2021

Finding 2019-001 Condition The testing sample of 44 students included 5 students who withdrew during the school year. Due to the exceptions noted in the sample of 5 withdrawals, the remaining 2 students who withdrew were selected for testing of the R2T4calculations. These 7 students represent 100% of the population of the students who withdrew. An incorrect beginning date of the semester was used for 6 of the R2T4 calculations. Of these 6 students, it was determined that the correct refund was understated on 4 of the calculations. Corrective Action Plan Corrective Action Planned: The financial aid office will work closely with the Registrar's Office to review the dates on the academic calendar and also withdraw dates to ensure accuracy of reporting return to Title IV calculations. Name of Contact Person Responsible for Corrective Action: Pam White, Director of Financial Aid Anticipated Completion Date: For the year ended June 30, 2020, all R2T4 forms will be carefully reviewed for correct dates.

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2015-002