Union Commonwealth UniversityNon-Profit

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

2024-003 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 Criteria: 34 CFR 685.203 states, "A first (second) (third) year student can receive up to $3,500 ($4,500) ($5,500) in subsidized loans in one academic year (34 CFR 685.203).” Condition: We tested 40 files, 37 of which were Federal Direct Loan recipients, and 1 student did not receive the full amount of her Federal Direct Subsidized Loans. Questioned Costs: $1,375 Cause and Effect: The result is a student received unsubsidized loans prior to receiving full subsidized loans. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding. All members of the Financial Aid Office staff will complete the loan learning track on the FSA training site. There will also be a refresher on steps to take prior to awarding a student to ensure the right credit hours are being used for Direct Loan recipients.

2023-003

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.” Condition: The College did not properly disburse direct loans for 1 out of 40 students (2.5%). Views of Responsible Officials: The financial aid office staff will complete the packaging aid and loans learning tracks on the Federal Student Aid Training Center. The staff will complete this training annually to ensure compliance of all regulations. Responsible Person: Andra Butler, Assistant Vice President of Financial Aid Implementation Date: October 2023

2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states “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 grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22). Condition: The College did not accurately complete refund calculations in the Spring. In review of the Spring 2023 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in Spring 2023 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 1 out of the population of 4 (25%) total withdrawal calculations. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Views of Responsible Officials: After years of completing a manual calculation we had switched to a full automated process. Going forward we will be completing a manual calculation to compare to the automated response to ensure the correct number of days are used. Responsible Person: Andra Butler, Vice President of Financial Aid Implementation Date: October 2023

Finding 2022-003 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.? Condition: The College did not report current enrollment status changes for 2 out of 40 students (5%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2021-002. Statistical sampling was not used in making sample selections. Corrective Action Plan: The reporting process has been corrected and in addition, the Registrar verifies the accuracy of this report internally with the College?s technology department before submitting it each month. Responsible Person: Andra Butler, Director of Financial Aid Preshus Howard, Registrar Implementation Date: November 2022

2021-002

Finding 2021-002 (Repeat Finding of 2020-005) Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Criteria: Per 34 CFR 685.309, unless the school expects to complete its next enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. The school is responsible for timely reporting whether they report directly or via a third-party servicer. Per 34 CFR 685.200, a borrower who completes an undergraduate program and who has not become responsible for accruing interest on Direct Subsidized Loans as a result of attendance in the program does not become responsible for accruing interest prior to completing that program. Condition: Out of a sample of eight students that withdrew with Direct Loans, the College failed to correctly notify the National Student Loan Data System (NSLDS) of one of the students' status changes. Additionally, out of a sample of 23 graduate status changes, the College failed to correctly notify the NSLDS of two students' status changes. Cause: The College did not have a control in place to ensure that timely reporting of all status changes is occurring. Effect: Without notification, the NSLDS is not timely updated of change in status for students who have withdrawn or graduated. Timely notification allows the NSLDS to determine when a student enters repayment status. We recommend that internal controls be established to verify that students who have received a loan and ceased enrollment are reported to the guaranty agency within a timely manner. Views of responsible officials and planned corrective actions: The College concurs with the finding. A reporting process error from our student information system, Jenzabar resulted in students with status changes not being reported to third party-servicer, Clearing House. The reporting process has been corrected and as a reinforcement of the data the Registrar verifies the accuracy of this report internally with the College?s technology department before submitting online each month. Further, our Director of Financial Aid now spot checks this reporting once every 8-week biterm using her NLSDS login for both undergraduate and graduate students with status changes. Estimated Completion Date: August 1, 2021 Responsible managers: Kather Inkster, Registrar and Andra Butler, Director of Financial Aid

2020-005

Finding 2021-003 (Repeat Finding of 2020-006) Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Pell Grant Program, CFDA 84.063 TEACH Program, CFDA 84.379 SEOG Program, CFDA 84.007 Criteria: Per 34 CFR 668.164(h)(2), when a Title IV credit balance occurs, it is the College's responsibility to pay or make available any credit balance within the 14-day regulatory time frame. Condition: Out of a sample of twenty-five students that received Title IV aid, the College failed to refund a credit balance within the required 14-day period for seven of the students. Cause: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Views of responsible officials and planned corrective actions: The College concurs with the finding, which was first disclosed in the delayed FY20 Single Audit by our auditors on May 13, 2021. In response to the finding, the College will change loan policies to ensure that any students with Title IV funds credit balances have those credit balances refunded within the appropriate time frame. In addition, the College has automated the refund process and the Controller reviews the credit balance report on a weekly basis to ensure that refunds are processed in a timely manner. Estimated Completion Date: July 1, 2021 Responsible manager: Jessica Justice, Controller

2020-006

Finding 2021-004 Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Criteria: Per 34 CFR 685.304, an Institution is required to ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS Loan. Condition: Out of a sample of 25 students, the College did not perform entrance counseling before the disbursement of direct loans for nine of the students. Cause: The College did not have a control in place to ensure that all students had completed entrance counseling before the disbursement of direct loans. Effect: The College is not in compliance with the U.S. Department of Education requirements for entrance counseling. Recommendation: We recommend that internal controls be established to ensure that all students who are awarded direct loans complete entrance counseling before the disbursement of loans. Views of responsible officials and planned corrective actions: The College concurs with the findings. Parameters have been updated on the PowerFAIDS software to not allow origination of direct loans without having completed entrance counseling on file. The importance of entrance counseling completion will be stressed at freshmen orientation. For the 2021-22 fall semester no loans have been originated without entrance counseling being completed. Estimated Completion Date: July 1, 2021 Responsible manager: Andra Butler, Director of Financial Aid

Finding 2021-005 Federal Program: U.S. Department of Education TEACH Program, CFDA 84.379 Criteria: Per 34 CFR 686.21, an Institution can award eligible full-time students up to $4,000 annually in Teach Grants. Condition: Out of a sample of two students, the College did not correctly award Teach grants to 1 student as the College awarded more than the annual limit of Teach Grant aid. Cause: The College did not have a control in place to ensure that all students were awarded the appropriate amount of Teach grants. Effect: The College is not in compliance with the U.S. Department of Education and has questioned costs of $713 due to inappropriate awarding of Teach grants. Recommendation: We recommend that internal controls be established to ensure that students are awarded the correct amount of Pell grants. Views of responsible officials and planned corrective actions: The College concurs with the finding. The Teach Grant was inadvertently awarded as a summer trailer instead of a summer header for the next award year. After census date the financial aid staff will double back and check students awarded with Teach Grant to ensure they are not awarded over the annual limit. Estimated Completion Date: October 2021 Responsible manager: Andra Butler, Director of Financial Aid

Finding 2021-006 Federal Program: Higher Education Student Aid COVID-19 - HEERF II, CFDA 84.425E Criteria: Per section 314(e) of the CRRSAA Act, all HEERF grantees that received a Section 314(e) student portion award are required to post information publicly on the institution's primary website quarterly. Reports are required to be posted within 10 days after the calendar quarter end. Condition: We noted that the College posted the required student quarterly reporting via College's website outside of the 10-day window as described in the CRRSAA Act. The College was required to reporting information related to HEERF II funds spent on students on a quarterly basis and make that information available to the general public within 10 days of the end of each quarter started after October 30, 2020. Cause: The College did not have a control in place to ensure timely reporting. Effect: The College was not in compliance with the reporting requirement within the CRRSAA Act. Recommendation: We recommend that the College implement a control that ensures timely reporting for all grants based on their requirements. Views of responsible officials and planned corrective actions: The College concurs with the finding. The College?s administration complied with the Q2 2021 quarterly institutional report on July 8th, yet due to a missed Department of Education update posted on May 13, 2021, did not report on the student portion of funds for Q2 2021 until September 30, 2021. This reporting control has been corrected as evidenced by the Q3 student report having been filed and published online on the College?s CARES Act web page on October 4, 2021. Estimated Completion Date: October 4, 2021 Responsible Manager: Brian Strunk, VP of Institutional Advancement & Enrollment Management

Finding 2021-007 Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Criteria: Per 34 CFR 668.22(b)(2) an attendance taking institution must document a student's withdrawal date and maintain the documentation to support the institutions determination of withdrawal within 14 days of a student's last date of attendance. Condition: During unofficial withdrawal testing, we selected a sample of two students from a population of 21 students. We noted that one of those two student's did not have a withdrawal calculation performed timely based on the student's withdrawal date. Cause: The College changed to an attendance taking institution for the year ended June 30, 2021. The College did not have a control in place to timely determine whether a return calculation was necessary. Effect: The College is not in compliance with the U.S. Department of Education requirements for a student who ceases attendance at an attendance taking institution. Recommendation: We recommend that the College implement a policy to ensure timely calculation of return of title IV funds based upon the rules of an attendance taking institution. Views of responsible officials and planned corrective actions: The College concurs with the finding. Our attendance policy is being updated to require faculty to consistently report attendance in each of their classes beginning with the Spring 2022 semester, and for faculty to report student gaps in attendance in violation of our policies to ensure compliance with the 14 day requirement in determining if Title IV funds need to be returned. Estimated Completion Date: January 2022 Responsible Manager: Marisa Greer, Vice President for Academic Affairs and Andra Butler, Director of Financial Aid.

Finding 2020-005 Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Criteria: Per 34 CFR 685.309, unless the school expects to complete its next enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. The school is responsible for timely reporting whether they report directly or via a third party servicer. Per 34 CFR 685.200, a borrower who completes an undergraduate program and who has not become responsible for accruing interest on Direct Subsidized Loans as a result of attendance in the program does not become responsible for accruing interest prior to completing that program. Condition: Out of a sample of five students that withdrew with Direct Loans, the College failed to correctly notify the National Student Loan Data System (NSLDS) of three of the students' status changes. Additionally, out of a sample of 24 graduates status changes, the College failed to correctly notify the NSLDS of six students' status changes. Cause: The College did not have a control in place to ensure that timely reporting of all status changes is occurring. Effect: Without notification, the NSLDS is not timely updated of change in status for students who have withdrawn or graduated. Timely notification allows the NSLDS to determine when a student enters repayment status. Recommendation: We recommend that internal controls be established to verify that students who have received a loan and ceased enrollment are reported to the guaranty agency within a timely manner. Views of responsible officials and planned corrective actions: The College concurs with the finding. The Registrar will check both withdrawn and graduated student reports to the Clearinghouse each month, to ensure that all submitted files have been received and recorded within the 60-day reporting requirement. Estimated Completion Date: June 22, 2021 Responsible manager: Kathy Inkster, Registrar

Finding 2020-006 Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Pell Grant Program, CFDA 84.063 TEACH Program, CFDA 84.379 SEOG Program, CFDA 84.007 Criteria: Per 34 CFR 668.164(h)(2), when a Title IV credit balance occurs, it is the College's responsibility to pay or make available any credit balance within the 14-day regulatory time frame. Condition: Out of a sample of twenty-five students that received Title IV aid, the College failed to refund a credit balance within the required 14-day period for fifteen of the students. Cause: The College did not have a control in place to ensure that timely refunds of credit balances occurred within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education. Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Views of responsible officials and planned corrective actions: The College concurs with the finding. The delay in return of credit balances due these students came as the result of a misinterpretation of ED guidelines regarding what constitutes permission by students to hold credit balances on their accounts due to expected future term expenses. These students were contacted by email about their credit balances, and instead of providing the credit upon their non-response, the College held their credit balance for use in the future term. In response to the finding, the Financial Aid Office and the Business Office have changed their refund procedures to only disburse student aid as it is utilized for bi-term classes, and to refund all credit balances to students within the 14-day timeframe without asking students if they wish to keep the credit on their account for a future term. Estimated Completion Date: June 22, 2021 Responsible manager: Andra Butler, Director of Financial Aid and Steve Morris, VP for Business and Financial Services

Finding 2020-007 Federal Program: U.S. Department of Education Direct Loan Program, CFDA 84.268 Pell Grant Program, CFDA 84.063 TEACH Program, CFDA 84.379 SEOG Program, CFDA 84.007 Criteria: Per 34 CFR 668.51, an Institution is required to perform verification procedures when a student's ISIR is selected for verification by the department of education. Condition: Out of a sample of 25 students, the College failed to perform verification procedures for one of the students. Cause: The College did not have a control in place to ensure that all students selected for verification were correctly verified. Effect: The College is not in compliance with the U.S. Department of Education and has questioned costs of $14,415 of due to awarding a student who was not properly verified. Recommendation: We recommend that internal controls be established to ensure that all students who are selected for verification are verified. Views of responsible officials and planned corrective actions: The College concurs with the finding. The student in question was a graduate student and had not been verified for V4. To correct the issue, graduate students for 2020-21 have been reviewed to ensure no verification request had been missed for V4 or V5 verification statuses. All members of the Financial Aid Office staff have completed FSA Verification training to ensure that everyone is clear on verification requirements. Estimated Completion Date: June 22, 2021 Responsible manager: Andra Butler, Director of Financial Aid

Finding 2020-008 Federal Program: U.S. Department of Education Pell Grant Program, CFDA 84.063 Criteria: Per 34 CFR 668.2, an Institution is required to award Pell grants to students based on their enrollment status, cost of attendance, and expected family contribution. Condition: Out of a sample of twenty-five students, the College did not correctly award Pell grants to 2 students. Cause: The College did not have a control in place to ensure that all students were awarded the appropriate amount of Pell grants. Effect: The College is not in compliance with the U.S. Department of Education and has questioned costs of $95 due to inappropriate awarding of Pell grants. Recommendation: We recommend that internal controls be established to ensure that students are awarded the correct amount of Pell grants. Views of responsible officials and planned corrective actions: The College concurs with the finding. The Office of Financial Aid has implemented a new policy and procedure to better ensure award Pell Grant based on the student?s cost of attendance. PowerFaids, the financial aid software, automatically packages Pell Grant based on the students expected family contribution, cost of attendance and their enrollment status based on hours. However, as an additional safeguard, the College will update internal policies and educate student financial aid staff to ensure that automatically packaged Pell awards are monitored to ensure they are awarded appropriately. Estimated Completion Date: June 22, 2021 Responsible manager: Andra Butler, Director of Financial Aid