Cisco College

Criteria: Per 34 CFR 685.301 (Federal Direct Loan Program), 34 CFR 690.83 (Federal Pell Grant Program), and the Federal Student Aid Handbook, institutions are required to report disbursement information to the COD system accurately and within the timeframes specified by the U.S. Department of Education. Timely and accurate reporting is necessary to ensure compliance with federal regulations and proper administration of Title IV funds. Condition: During our testing of the Student Financial Aid Cluster, we noted that the institution did not consistently submit student disbursement records to the COD system in a timely and accurate manner for both the Federal Direct Loan and Federal Pell Grant programs. Specifically, 6 out of 40 disbursement records tested were either submitted after the required deadline or contained errors that were not corrected promptly. Population and Sample Size: Number Dollars Questioned Cost Population 1320 $ N/A $ N/A Sample 40 N/A N/A Not in compliance 6 N/A N/A Effect: As a result, the institution is not in compliance with federal requirements for reporting to the COD system for both the Federal Direct Loan and Federal Pell Grant programs. This could result in delayed or improper disbursement of Title IV funds, potential loss of funding, or other administrative sanctions. Cause: The District updated the financial aid records in the internal student system but did not update the dates in COD in a timely manner. Recommendation: We recommend that the District strengthen reconciliation procedures to ensure that all loan changes entered in the internal system are promptly updated in COD and periodically verify that key data elements match.

Criteria: In accordance with CFR section 685.309(b)(2), "Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended." Condition: We reviewed a sample of 40 students who received financial aid during the fiscal year. Of the 40 students tested, eight students withdrew and were not accurately reported to the NSLDS within the required 60-day period. Ten students graduated and were reported after the 60-day requirement. The other two students dropped to less than half-time and the status was not reported within the 60-day requirement. Population and Sample Size: Number Dollars Questioned Cost Population 1,355 $ N/A $ N/A Sample 40 N/A N/A Not in compliance 20 N/A N/A Effect: A student's enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies, all of which are negatively impacted by inaccurate and late reporting. Cause: The District did not have a process in place to transmit reports to NSLDS during the time between the prior registrar’s retirement and the hiring of their replacement. Recommendation: We recommend that at each NSLDS upload date, management review the NSLDS enrollment reporting upload to ensure student withdrawals during the period are appropriately reported in a timely manner.

Criteria: In accordance with CFR section 676.20(a)(1), "An institution may award an FSEOG for an academic year in an amount it determines a student needs to continue his or her studies. However, except as provided in paragraph (c) of this section, an FSEOG may not be awarded for a full academic year that is less than $100." Condition: We reviewed a sample of 4 students who received FSEOG during the fiscal year. Of the 4 students tested, three students were awarded amounts less than the $100 minimum award. Effect: The College fell out of compliance with the FSEOG regulations by disbursing amounts below the minimum award limit. Cause: Management did not identify the correct limits outlined by the award. Recommendation: We recommend that each award amount be reviewed as within the limits outlined in the compliance documents.

Criteria: In accordance with the Student Financial assistance cluster from the 2024 compliance supplement, "Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner." Condition: We reviewed a sample of 40 students who received financial aid. Out of the 40 students tested, 23 students cost of attendance per the student records did not agree to the amounts reflected in COD originations records. Effect: Incorrect or late reporting to the Common Origination and Disbursement (COD) System can lead to serious consequences for both institutions of higher education and their students. For institutions, delays in reporting may hinder access to federal funds, disrupt cash flow, and delay financial aid disbursements to students. Persistent errors can increase administrative burdens, require extensive corrections, and may lead to heightened scrutiny, such as being placed on Heightened Cash Monitoring (HCM) by the U.S. Department of Education (ED). Compliance failures can also damage an institution's reputation among prospective students and stakeholders. For students, these issues can result in delayed receipt of financial aid, insufficient or excessive funding, and complications with loan repayment, servicing, or eligibility for loan forgiveness. Timely and accurate reporting is critical to avoid these challenges and ensure smooth operations and compliance with federal regulations. Cause: The District relied upon data exported from EDExpress to be accurately imported to COD. An error in the software caused inconsistent data to be pulled into the required fields, and the imports were not reviewed in detail. Recommendation: We recommend that COD information is reviewed by an individual independent of the reporting process to verify that the amounts reported are accurate with the source data.

See Schedule of Findings and Questioned Costs for chart/table Criteria: In accordance with CFR sections 668.22(a)(2)(i): "Except as provided in paragraphs (a)(2)(ii) and (a)(2)(iii) of this section, a student is considered to have withdrawn from a payment period or period of enrollment if (A) In the case of a program that is measured in credit hours, the student does not complete all the days in the payment period or period of enrollment that the student was scheduled to complete; (B) In the case of a program that is measured in clock hours, the student does not complete all of the clock hours and weeks of instructional time in the payment period or period of enrollment that the student was scheduled to complete; or (C) For a student in a nonterm or nonstandard-term program, the student is not scheduled to begin another course within a payment period or period of enrollment for more than 45 calendar days after the end of the module the student ceased attending, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section." Condition: To test Return to Title IV (R2T4) calculations, we obtained a listing of students for whom the College ran an R2T4 calculation. To test the completeness of this listing, we obtained a listing of students who withdrew as well as a listing of students who withdrew (W) or received a failing (F) grade in every class during a semester. Two (2) Students were identified that received all F's or W's that were not included in the R2T4 listing. See Schedule of Findings and Questioned Costs for chart/table Effect: A student who withdraws from the institution without giving notice of their withdrawal would receive all F's or W's for the semester. These students are not being properly identified. Aid that should be returned is not being returned due to the listing used not being complete. Cause: The College will identify all students who formally withdraw for a calculation of R2T4 funds. For students who do not formally withdraw, the College runs a report at the end of the semester to identify students who did not receive a grade higher than an F for the semester. The report only shows the date of drop the last drop which often is the last date of the semester as professors will leave students enrolled until the end. The College assumes these students dropped after the 60% date and does not perform an R2T4 calculation. Recommendation: We recommend the college develop a report in their IT system to list only those students that receive all F?s or I?s each semester for ease in identifying possible R2T4s. We also recommend the College require professors to keep attendance to identify students who have withdrawn from the class. Views of responsible official and planned corrective actions: Cisco College?s Financial Aid Department will create a weekly report of students withdrawing. If the students are still registered in other courses, the Financial Aid Department will contact the instructor to see if the student is still attending. If the student is not attending, the instructor will drop the student for non-attendance and the Financial Aid Department will process the R2T4. At the end of each semester, the Financial Aid Department will also review a report of all students who are receiving grades of ?F? or ?I?. Cisco College?s Instructional Administration will send reminders to all full-time and adjunct faculty at midterm, as well as the last day to drop with a ?W?, to check the attendance of their students and drop accordingly. This increased communication is intended to find students who are not attending and have them withdrawn earlier in the semester for R2T4 purposes.

2020-001 Cluster Name: Student Financial Aid Cluster CFDA Numbers and Names: 84.007 Federal SEOG, 84.033 Federal Work Study, 84.063 Federal Pell Grant, 84.268 Federal Direct Loans Federal Agency: U. S. Department of Education Compliance Requirement: Enrollment Reporting Questioned Costs: Not applicable Criteria: In accordance with CFR sections 674.19(f), " Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended." Condition: We reviewed a sample of forty-eight (48) students who withdrew during the fiscal year. Of the forty-eight (48) students tested, sixteen (16) students were reported to NSLDS either inaccurately or untimely. Of the sixteen (16) students, six (6) students incorrectly reported to the NSLDS as withdrawn when they had actually graduated. Fourteen (14) students were reported using an accurate withdrawal date but were not reported to the NSLDS within the required timeframe. The changes were reported from nine (9) to one hundred thirty-eight (138) days after the student status changes had occurred. Population: 3,260; Sample Size: 48; Not in compliance: 16; Dollars: N/A; Questioned Cost: N/A Effect: A student's enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are negatively impacted by inaccurate and late reporting. Cause: The process for tracking and processing a change in enrollment is the responsibility of the District. The Central Registrar's office maintains the existing policy and procedure to report every thirty (30) days to NSLDS, but is reliant on the information tracked and input by the administrators at each school. Six (6) students were incorrectly reported as withdrawn in the system when they actually graduated. This is due to an error in the report being run from the District?s IT system. The exact cause of this error is not yet known. Fourteen (14) students were not reported to the NSLDS within the required sixty (60) day time limit due to the students not being enrolled in summer courses. The District did not continuously report enrollment data for all students during the summer months, they only reported students who were enrolled in classes currently. This led to enrollment status changes not being reported for four (4) months.