Berry College

Finding 2025-001 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: E. Eligibility - Cost of Attendance - For Title IV programs, the cost of attendance is generally the sum of the following: tuition and fees; an allowance for books, course materials, supplies, equipment, transportation, and miscellaneous personal expenses; an allowance for food and housing; when applicable, allowances for costs for dependent care; cost of obtaining a license, certification, or a first professional credential; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for Federal student loans (34 CFR 668.43). Condition: For 5 students selected for testing, the student’s estimated cost of attendance was not properly calculated. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with requirements for calculating cost of attendance. Questioned Costs: $0 Context: 5 out of 25 students selected for testing. Identification of Repeat Finding: There were no similar findings identified during the prior year. Recommendation: We recommend the College enhance its procedures over cost of attendance to ensure it is calculated correctly. Views of Responsible Officials: Management agrees with the finding that the estimated Cost of Attendance (COA) for the summer term was calculated incorrectly for five students. Because the summer term includes multiple sessions, the COA multi-step programming process in PowerFAIDS, the College’s financial aid management software, including the review of COA selection metrics, are manual. In April 2025, the College migrated its ERP software and PowerFAIDS to cloud-based platforms. This transaction required significant time from Office of Financial Aid (OFA) staff to test system functionality and validate migrated data to ensure a smooth go-live. As these efforts coincided with summer COA programming, the capacity for thorough review and comprehensive functional testing of summer COA setup was reduced. Going forward, the OFA will assign a staff member, separate from the individual handling COA programming, to review the COA selection metrics. In addition, the OFA will evaluate the potential of automating COA programming processes.

Finding 2025-002 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Notification of Disbursements - When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. Condition: For 1 student selected for testing, a disbursement notification was not sent to the student or parent within the required timeframe of 30 days. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with the requirements for notifying students or parents of the disbursement of federal loan funds to their account. Questioned Costs: $0 Context: 1 out of 25 students selected for testing. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College notify students or parents within the 30 day period. Views of Responsible Officials: Management acknowledges that for one student, the required federal direct loan disbursement notification was not sent within the required timeframe. After the parent’s PLUS loan was denied in April 2025, the student was offered an additional unsubsidized loan, which was accepted on 5/7/2025. The manually generated notification for the 5/8/2025 disbursement was inadvertently missed being sent out. We believe this oversight was an isolated incident due to the OFA’s unusually demanding April/May as noted in the previous finding. To mitigate this issue going forward, the OFA will remove the need for manual intervention by implementing an automated notification process utilizing the built-in scheduler functionality in PowerFAIDS.

Finding 2025-003 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: For 1 student selected for testing, certain key elements at the Program-Level were not correctly reported to the NSLDS. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with the requirements of Program-Level enrollment reporting. Questioned Costs: $0 Context: 1 out of 25 students selected for testing. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Management agrees with the finding that one student’s Program Begin Date was incorrectly reported to NSLDS. For this new student, the Program Begin Date was reported as 5/14/2021, the date the new student transitioned from admissions to registration, rather than the actual first day of the academic term in which the student began enrollment in the program, as required by Part 5 of the 2025 Compliance Supplement. Beginning with the 2020 OMB Compliance Supplement, enrollment reporting requirements were expanded to include additional compliance data elements for NSLDS. During the 2020-2021 award year, the National Student Clearinghouse (NSC), the College’s third-party servicer for enrollment reporting, encountered program level data integrity issues. In response, new warning codes were introduced in December 2021, including WC 1811 Series, which addresses mismatch flags in Program Begin Date. In this case, however, no warning flag was triggered for the student. The Registrar Office will follow up with NSC to identify why the warning flag did not trigger. Moving forward, Registrar Office staff will review enrollment reporting files to verify that each student’s Program Begin Date reflects the first day of the term in which the program enrollment began, unless the student’s enrollment in the program was on an earlier date.

Federal Program Information: Student Financial Aid Cluster Criteria or Specific Requirement: Sepcial Tests and Provisions: Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System (DLSS) via the COD within 15 days of disbursement Condition: For 1 student selected for testing, the College did not submit the required records to DLSS within the required 15-day timeframe after adjusting the loan on the student?s account. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with requirements related to special tests and provisions. Questioned Costs: $0 Context: 1 out of 25 students selected for testing Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College submit the required records to DLSS within the 15 day period.

Finding 2020-001 Federal Program Information: Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (CFDA 84.425E) Criteria or Specific Requirement: Activities Allowed and Unallowed: Students who are or could be eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (?HEA?), may receive emergency financial aid grants. Condition: In the process of the College?s review of students receiving the HEERF Student Aid, the College identified 31 students who received a HEERF grant who were ineligible. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with requirements related to allowable activities. Questioned Costs: Below reporting threshold. Context: 31 of 976 students who received a HEERF grant. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College undertake a review of all students who receive future HEERF grants to determine eligibility prior to distribution of funds. Views of Responsible Officials: Management agrees with the self-identified finding. As stated, in the finding condition, the ineligibility of the 31 students was identified by college staff during the review of data for the HEERF annual report. The certification agreement directed institutions to promptly distribute grants to students and in her letter dated April 9, 2020 to grantees receiving HEERF funds, the Secretary of Education asked that institutions prioritize students with the greatest need while ensuring the funds were distributed as broadly as possible. Lack of clarity about eligibility requirements due to the inconsistent guidance during the development of the distribution strategy, made student eligibility review difficult, as this process was occurring concurrently with College staff complying with changes to other federal requirements, fielding questions from students and parents related to the disruption on campus due to the coronavirus, and coping with the unprecedented transition to remote work and operations. By the time the annual report was due in February 2021, final guidance had been released and the financial aid staff were able to devote time to perform a more detail review of student information relative to the grants. Upon determination of the ineligibility, HEERF funds for the 31 students were replaced with institutional funds and grant funds ($24,200) were subsequently redistributed to eligible students. The annual CARES Act: Education Stabilization Fund report was completed accordingly. Management believes this is an isolated incident. Extra diligence has been applied to the HEERF II distribution with verification by three independent offices confirming student eligibility prior to the distribution of funds.

Federal Program Information: Federal Direct Student Loan Program (CFDA #84.268) & Federal Pell Grant Program (CFDA #84.063) Criteria or Specific Requirement: Special Tests and Provisions ? Enrollment Reporting: An institution is required to update students? changes in status on the National Student Loans Data System (?NSLDS?) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309). If the roster file submitted to the NSLDS does not pass the NSLDS enrollment reporting edits, the school will receive an error file with the records that did not pass. Any errors must be corrected and submitted within 10 days of receiving the error file from NSLDS (IFAP Federal Student Aid Handbook, Volume 2, Chapter 3). Condition: During our testing of enrollment reporting, we noted the following exceptions: - For 4 of the 40 students sampled, the College did not certify the student?s graduation status timely. - For 1 of the 5 NSLDS error reports received with errors, an error was not corrected timely. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with enrollment reporting requirements. Questioned Costs: None. Context: We tested a sample of 40 students and found four exceptions as noted in the condition. This is a condition identified per review of the College?s compliance with specified requirements using a statistically valid sample. Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-001 in the 2018 report. Recommendation: We recommend that the College ensure its policies and procedures are followed on a consistent basis. Views of Responsible Officials: Management agrees with the finding. Exceptions are carry-over issues from last year?s Finding 2018-01 related to the staff being unaware of a change in National Student Clearinghouse (NSC)?s G from DV process which did not allow the graduated status to be applied to the student enrollment record should there be mismatched degree data. Effective October 26, 2018, the Registrar?s Office began submitting graduated statuses via enrollment reporting rather than utilizing NSC?s G from DV add-on service.

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the NSLDS Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: During our testing of mid-year transfer students, we noted the following exceptions: - Two of the 3 students sampled were not added to the NSLDS Transfer Monitoring List. Cause: Policies and procedures were not appropriately adhered to in certain instances to ensure that NSLDS was informed of the College?s transfer students as required. Effect or Possible Effect: The College was not in compliance with required federal guidelines. Questioned Costs: None. Context: We tested a sample of 3 mid-year transfer students and found two exceptions as noted in the condition. This is a condition identified per review of the College?s compliance with specified requirements using a statistically valid sample. Recommendation: We recommend that the College ensure its policies and procedures are followed on a consistent basis. Views of Responsible Officials: Management agrees with the finding. Although the Financial Aid Office monitored the two mid-year transfer student exceptions and maintained documentation in the students? files substantiating review of the requested financial aid history using NSLDS student transfer monitoring process, a batch file to be submitted to NSLDS was not generated by PowerFAIDS, the College?s financial aid management software. To ensure all transfer and re-admitted student records have been both generated by PowerFAIDS and received by NSLDS, an audit process has been put in place by the Financial Aid Office to identify all records without proper PowerFAIDS statuses ?inform file exported? and inform file acknowledgement.?

Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement: Special Tests and Provisions ? Return of Title IV Funds - 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. Condition: During our testing of R2T4 calculations, we noted the following exception: - For 1 of the 3 students sampled, the College used the incorrect number of days in term/payment period. Cause: Administrative oversight. Effect or Possible Effect: The College was not in compliance with required federal guidelines. Questioned Costs: None. Context: We tested a sample of 3 withdrawn students and found one exception as noted in the condition. This is a condition identified per review of the College?s compliance with specified requirements using a statistically valid sample. Recommendation: We recommend that the College exclude institutionally scheduled breaks of five or more consecutive days from its R2T4 calculations. Views of Responsible Officials: Management agrees with the finding. Although, we believe this was an isolated incident, an additional control will be added to ensure that R2T4 amounts have been calculated correctly. Going forward, the Financial Aid Office will serve as secondary reviewer for R2T4 calculations prepared by Student Financial Services.

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