DALLAS CHRISTIAN COLLEGEHigher Education

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: When students withdrew unofficially, the College did not always return unearned Title IV aid accurately and/or timely. Criteria: 34 CFR 668.22 Questioned Costs: $1,233 Context: Out of 9 students, 1 student who withdrew during the audit period tested had funds returned late due to misapplication of withdrawal regulations when a student does not begin attendance at least half time due to not beginning attendance in a class they were scheduled to attend. Another student had a correct calculation but the incorrect amount of a post-withdrawal disbursement of Pell resulting in $1,233 to return to the government. One unofficial withdrawal had the incorrect calendar used, and therefore, over returned $24 of federal direct loans. One student had all federal direct loan funds returned, resulting in an over return of $2,945 of loans. These students are in the process of being corrected. Cause: The College had some system notifications in place, but they were not sent timely and accurately to be shared with the third-party servicer, and the director of financial aid was not aware that not all information was being shared correctly. This resulted in misapplications of modular unofficial withdrawal students. Additionally, there was an incorrect calendar set up used for a type of student resulting in an inaccurate return. Effect: Incorrect amount of unearned Title IV funds was returned. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College work with the third-party servicer to ensure accurate and timely information is shared to effectively and efficiently process the returns of federal funds. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 - Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College had not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) during the fiscal year to comply with 16 CFR 314.4(c)(5). Subsequent to year-end, all but one system has MFA added. Cause: For the system that did not allow MFA natively in the prior year, a new system was identified, and the College moved to the new system shortly after fiscal year end. There is one additional system that the College is working to implement MFA as soon as possible. We commend the College for the substantial work done during the year. Effect: The College may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the College implement MFA on the one remaining system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Need Analysis and Estimated Financial Assistance DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need based federal financial aid due to certain estimated financial assistance being set up as non-need based aid. Criteria: 34 CFR 685.203 Questioned Costs: $3,512 Context: Two students out of 51 were over awarded subsidized loans. Cause: Some institutional scholarships are set up as non-need based aid but not flagged as estimated financial assistance, so systematically it looked like there was need when need had been met. Effect: Students not awarded need based federal aid according to eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure that all scholarships are flagged as estimated financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) correctly for one student. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 51 students tested, 1 student who withdrew after the fall semester was not reported as withdrawn. This was corrected during the audit process. Cause: This was an oversight. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2022-002. Recommendation: We recommend the College put a system in place to ensure that students who leave after one semester are reported as withdrawn and that the College is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The FDL amounts posted to student account did not always agree to disbursement records reported to Common Origination and Disbursement (COD) for one student. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: One of 51 students tested, 1 student had a COD loan disbursement amount error of approximately $1,000 that was not caught in the monthly reconciliation. Cause: There was a miscommunication between the third party administrator and the College, and the monthly reconciliation process did not identify the discrepancy. Effect: Inaccurate FDL reporting can impact a student’s interest accumulating period based on the dates and amounts of the loan disbursement dates as well as the monitoring of FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Yes, see 2022-003. Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts and that all dates and amounts be part of the monthly reconciliation process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College returned Title IV funds for a modular student withdrawal that did not require funds to be returned based on the completion rate. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 11 R2T4s tested, 1 student had $2,318 returned in unsubsidized federal direct loans returned though the student was eligible to retain their Title IV funds as they had dropped the second and third modules prior to the start of the second module resulting in the payment period being only the first module. Cause: There was an oversight when the student dropped the remaining modules while still enrolled in the first module, resulting in a calculation based on the whole semester instead of the one module. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College review the timing of drops for those students taking classes in modules to determine the period of enrollment to be used for the return calculation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College did not report enrollment information to the NSLDS correctly for all students. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 57 students tested, 2 students had incorrect effective dates reported for their enrollment status, and 1 student was reported as half time instead of graduated. The two incorrect effective dates were both Fall 2021 official withdrawals. Cause: One student had a degree conferred on the transcript while the system showed the student as exited, so it was not picked up correctly for NSLDS reporting as graduated. The withdrawal students were not captured correctly based on their official withdrawal date with differences ranging from a couple of weeks to two and a half months different. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College put a system in place to ensure that the date being reported to NSLDS as the effective date of withdrawal is the actual official withdrawal date for the student, and that when degrees are conferred on the transcript the College is updating the status to graduated so the students are correctly picked up for enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

2022-003 Common Origination and Disbursement (COD) Dates Not Reflecting Actual Disbursement Dates DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for summer 2022 Federal Direct Loans (FDL) to COD. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 3 of 51 tested had COD loan disbursement date errors ranging from 23?77 days, with all errors in the summer 2022 term. There were no errors in the amounts reported, just the date of disbursement. All three students were corrected during the audit process. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that FDL were disbursed to the students? accounts. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

2021-001 Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Two students out of 32 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $793 Context: One student was inadvertently awarded and paid Pell for one more class than they attended. This was corrected during the audit. One student had not used their full annual Pell eligibility due to enrollment less than full time and was not awarded Pell for summer. This student was eligible for $725. Cause: These were oversights. Effect: There was an incorrect amount of Pell paid to these two students. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

2021-002 Late Responses to SCHER 1 Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The College did not respond timely to error records in National Student Loan Data System (NSLDS) reporting. Criteria: 34 CFR 685.309(b) Questioned Costs: $0 Context: Errors are required to be responded to within 15 days. One response was two days late due to the Christmas holiday break. One error rate in the summer was not responded to. Cause: This was an oversight with holidays and summer break. Effect: Students were not resolved timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond timely to all error records. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

2020-001 Incorrect and Untimely Return of Title IV Funds DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063 Federal Direct Student Loans, Federal Pell Grants Federal Award Identification #: 2019-2020 Financial Aid Year Condition: 1 of 22 students who were withdrawn did not have federal funds returned timely. Additionally, 1 student inadvertently had the Pell grant returned with the loans required to be returned. Criteria: 34 CFR 668.22 (e) and 34 CFR 668.22 (j)(1) Questioned Costs: $-0- Context: The financial aid department was not notified of an administrative withdrawal for one student until December, which resulted in the funds being returned late. Additionally, the Pell grant for one student in the amount of $706 was inadvertently returned during the R2T4 process when the loan funds were correctly returned. The $706 is not able to be drawn as the award year has been closed out. Cause: A lack of timely communication from the registrar?s office related to the administrative withdrawal resulted in the late return. Additionally, as the Pell was input in the R2T4 form as aid that could have been disbursed, it was inadvertently returned. Effect: One student had a late return, and one student did not receive the appropriate Pell that had been earned. Identification as repeat finding, if applicable: Yes, 2019-002 Recommendation: We recommend the financial aid office and registrar?s office verify all administrative withdrawals are automatically flagged for review by financial aid personnel. We also recommend a double check be done for any aid that could have been disbursed to ensure the aid is disbursed if calculated as earned in the R2T4 process. Views of Responsible Officials: Management is in agreement with the finding and is in the process of resolving the issue. See attached corrective action plan.

2019-001 Administrative Capability Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033, and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2018-2019 Financial Aid Year Condition: The College is evaluated as a whole on its ability to maintain compliance with Title IV regulations. The administrative capability was not adequate to properly maintain compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: See findings 2019-002 through 2019-004 Context: A number of the compliance regulations require accurate information from other departments timely. When the system is not accurately capturing and using the data, or when there are input errors from other departments, manual intervention is required to maintain compliance. We found multiple instances where noncompliance with regulations was identified. The systems used do not appear to be designed appropriately for the current level of staffing for financial aid. Effect: Noncompliance with Title IV regulations. Cause: Incorrect data inputs by other departments into the system and incorrect programming of flags for students who do not attend all of terms in the flex schedule for which they initially registered. Identification as repeat finding, if applicable: Yes, 2018-001 Recommendation: We recommend the College adjust the system programming and provide additional training on data inputs. Views of Responsible Officials: Management is in agreement with the finding and is in the process of resolving the issue. See attached corrective action plan.

2019-002 Missed Return of Title IV Funds Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063 Federal Direct Student Loans, Federal Pell Grants Federal Award Identification #: 2018-2019 Financial Aid Year Condition: Four of six students did not complete their initially scheduled modules and required a return of federal funds. The College has 30 days from the end of a term to determine if students have unofficially withdrawn and return funds. Criteria: 34 CFR 668.22 (e) and 34 CFR 668.22 (j)(1) Questioned Costs: $12,259 Context: Students can register for one or more modules within the term in the Flex program. When students fail to begin attendance in the next scheduled module, they are administratively withdrawn if they have not provided written confirmation of future attendance. These four students were administratively withdrawn but did not have a return calculation performed which resulted in the returns being made late. Depending on the Flex class, this date was around the middle of May, which gives the College until the beginning of August to return funds before they were considered late. These students were corrected during the audit process. Effect: The College did not initially calculate the return of Title IV funds. Cause: The student?s schedule and class attendance was not used to determine if a return was required. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend attendance records and class schedules be used to calculate potential R2T4?s whenever and administrative withdrawal occurs. Views of Responsible Officials: Management is in agreement with the finding and is in the process of resolving the issue. See attached corrective action plan.

2019-003 National Student Loan Data System (NSLDS) Enrollment Reporting Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2018-2019 Financial Aid Year Condition: Enrollment status was not always updated correctly to the National Student Loan Data Service (NSLDS). Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was inaccurate for 9 students out of the 53 tested. Out of the 9 exceptions, 8 of them affected repayment status. 6 of the 8 students were unofficial withdrawals where the last date of attendance was not used to report the student as withdrawn. Since the College is an attendance taking institution, the last date of attendance is required to be used. One student who did not return after fall was reported as full-time through spring, resulting in extra months of deferment. One student was reported as full-time through spring when they graduated after fall, resulting in extra months of deferment. All students were corrected during the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning loan repayment, appropriate interest charges, etc. Cause: The dates being used to gather the last date of attendance is not actual last date of attendance from attendance records. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College add a step to the withdrawal checklist for all withdrawals to ensure NSLDS is properly updated. We further recommend graduation rosters be compared to NSLDS to ensure all graduated students are correctly reported. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.

2019-004 Noncompliance with Community Service Requirement DEPARTMENT OF EDUCATION CFDA #: 84.033 Federal Work Study Federal Award Identification #: 2018-2019 Financial Aid Year Condition: The College failed to place enough students in the federal work study program to meet the requirement of having students working in community service as reading or math tutors. Criteria: 34 CFR 675.18(g) Questioned Costs: $-0- Context: The College placed additional students in positions that qualified to meet the community service requirements. However, the students worked less than they had been scheduled, and as a result, the College was a little bit below the required amount of community service, and the College appropriately did not draw those funds. It was a significant improvement from the prior year. Effect: Noncompliance with federal work study requirement Cause: The College was unable to find and place sufficient students to work to ensure compliance with the community service requirements. Identification as repeat finding, if applicable: Yes, see 2018-004 and 2017-002 Recommendation: We recommend the College place additional students in community service positions in order to ensure such requirements will be met in the future. We further recommend the wage rate be increased to attract additional workers. Views of Responsible Officials: Management is in agreement with the findings and is in the process of resolving this issue. See attached corrective action plan.

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