HILLSBOROUGH COUNTY SCHOOL DISTRICTLocal Government

Criteria or Specific Requirement: For Title IV programs, the cost of attendance (COA) is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation and miscellaneous personal expenses; an allowance for room and board; where applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. There are exceptions for students attending less than halftime, correspondence students, and incarcerated students. The financial aid administrator also has authority to use professional judgment to adjust the COA or alter the data elements used to calculate the expected family contribution (EFC) on a case-by-case basis to allow for special circumstances. Calculate the Pell COA: This is always based on the cost for a full-time enrollment status for a full academic year. If the student is enrolled in a program or enrollment period that is longer or shorter than an academic year, the costs must be prorated so that they apply to one full academic year. There are two allowable proration methods. Costs can be on an actual cost-per-student basis or an average cost for groups of similar students. If the student is enrolled less than half-time, the only allowable cost componentsare tuition and fees, allowance for books and supplies, transportation allowance, allowance for dependent care, and room and board. Condition Found: Of the 40 students selected for eligibility testwork, we identified 21 instances of incorrect COA calculations, as these calculations were based on full-time enrollment (900 clock hours) rather than taking into account the actual number of clock hours enrolled in by the student, resulting in their COA being calculated at a higher value. Cause and Possible Asserted Effect: The District?s system of internal controls did not include processes to review the COA amounts recorded for Pell recipients. As a result, incorrect COA amounts were calculated. Questioned Costs: None. The Pell award amounts were not affected by the incorrect COA calculation by more than $25,000 for the total population of students. Whether the Sample Was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Was a Repeat Finding in the Immediately prior Audit: No similar findings were noted in the prior year audit report. Recommendation: We recommend the District review and enhance their internal controls over the review of the Pell COA calculations prior to Pell awards being disbursed. View of Responsible Officials: To correct the COA calculation process, our Campus Information System (CIS) programmer will add enhanced features to calculate the COA to reduce potential human error. An additional feature will also be added into the CIS to alert the Financial Aid users to document any unmet need that falls below the normal levels.

Criteria or Specific Requirement: All schools receiving Pell grants must submit Pell origination records to the U.S. Department of Education through the COD (Common Origination and Disbursement) System. Key items to test on origination records are: Social Security Number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Key items to test on disbursement records are disbursement date and amount (34 CFR 690.83; FSA Handbook). Condition Found: Of the 40 students selected for Pell reporting testwork, we identified 18 instances where the information per the student records did not match the information per the COD. Cause and Possible Asserted Effect: The District?s system of internal controls did not include sufficient processes to review student information that was reported to the COD to ensure accurate student information was submitted in a timely manner. Questioned Costs: None. Whether the Sample Was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Was a Repeat Finding in the Immediately prior Audit: No similar findings were noted in the prior year audit report. Recommendation: We recommend the District review and enhance their internal controls over the COD reporting process. View of Responsible Officials: The District will enhance existing control activities surrounding the timely and accurate reporting of student information to the COD.

Criteria or Specific Requirement: Under the Pell grant and ED loan programs, institutions must complete and return within 15 days of the Enrollment Reporting roster file [formerly the Student Status Confirmation Reports (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file but the minimum is once every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition Found: Of the 25 samples selected for enrollment reporting testing, we identified nine instances where the District did not submit the student?s status change to NSLDS within 60 days of the District becoming aware of the change, five instances where the incorrect status change date was submitted to NSLDS, and six instances where the District did not submit the status change at all. All instances were related to students enrolled at Erwin Technical College. Cause and Possible Asserted Effect: For all students enrolled at Erwin Technical College, the status change information is sent to the Federal Clearinghouse who then sends then information to NSLDS. The District?s process does not include sufficient procedures to follow-up on submissions rejected from the Federal Clearinghouse, resulting in late enrollment reporting. Questioned Costs: None. Whether the Sample Was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Was a Repeat Finding in the Immediately prior Audit: No similar findings were noted in the prior year audit report. Recommendation: We recommend the District review and enhance their internal controls over the review of Federal Clearinghouse submissions and rejections to ensure timely enrollment reporting submissions. View of Responsible Officials: The District will enhance existing control activities surrounding the timely and accurate enrollment reporting of student status changes to the NSLDS.

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