Western Texas College

2020-001 Cluster name: CFDA numbers and names: Federal agency: Compliance requirement: Questioned Costs: Student Financial Assistance Cluster 84.007 - Federal Supplemental Educational Opportunity Grants 84.033 - Federal Work-Study Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Special Tests and Provisions - Enrollment Reporting None Criteria: In accordance with CFR sections 67 4.19(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 50 students who withdrew or had other enrollment status changes during the fiscal year. Of the 50 students tested, 14 students were not reported to the NSLDS or were reported either inaccurately or untimely. Of the fourteen (14) students, two (2) students were never reported as enrolled. Three (3) students were incorrectly reported to the NSLDS as withdrawn when they had actually graduated. 10 students were reported using an accurate withdrawal date but were not reported to the NSLDS within the required timeframe. The changes were reported from 7 to 130 days after the student status changes had occurred. Cause: The process for tracking and processing a change in enrollment is the responsibility of the College. The Central Registrar's office maintains the existing policy and procedure to report every 30 days to NSLDS, but is reliant on the information tracked and input by the administrators at each school. Three (3) students were never reported to the NSLDS due to the students having errors on their account initially. When the errors were corrected by the financial aid office, the corrections were never fixed in the enrollment reporting system. When the reports were run, they were programmed to be excluded due to the error not being removed. Three (3) students were incorrectly reported as withdrawn in the system when they actually graduated.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 College's IT system. The exact cause of this error is not yet known. Ten (10) students were not reported to the NSLDS within the required 60 day time limit due to the students not being enrolled in summer courses. The College 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 months. 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. Recommendation: We recommend the College implement a secondary review process of enrollment reporting as well as reinforce its policies and procedures by continuing to provide training to individuals involved in the process, specifically those responsible for inputting enrollment changes into the system, to ensure the NSLDS records are updated timely and accurately. Views of responsible official and planned corrective actions: Western Texas College will implement a process where the Systems Analyst will extract enrollment data from our Student Information System monthly listing students' enrollment status for the current semester. Errors will be corrected in the National Student Loan Data System (NSLDS) by the Registrar after the National Student Clearinghouse has processed each month's data, and errors have been returned to WTC. 62 Because the exact cause of the error resulting in incorrect enrollment status is not yet known, Western Texas College is investigating and will implement procedures to correct the cause of erroneous enrollment reporting. We are also working with the Vendor that provides our Student Information System to find a solution to report enrollment status for students who are not enrolled in the current term but are expected to return the following term.

2020-002 Cluster name: CFDA numbers and names: Federal agency: Compliance requirement: Questioned Costs: Student Financial Assistance Cluster 84.007 - Federal Supplemental Educational Opportunity Grants 84.033 - Federal Work-Study Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Special Tests and Provisions - Return of Title IV Funds $22,559 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 non-term 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 failed (F), withdrew (W), or received an incomplete (I) grade in every class during a semester. 2 Students were identified that received all F's or l's that were not included in the R2T4 listing. 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 maintain Satisfactory Academic Progress (SAP) during the semester. The financial Aid office will pull the transcripts of each student not maintaining SAP standards to identify students that received all F grades. The College generally assumes the students who receive F grades are earned F's rather than unearned F's from a withdrawal. Effect: A student who withdraws from the institution without giving notice of their withdrawal would receive all F's or l'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. Recommendation: We recommend the College develop a report in their IT system to list only those students that receive all F's or l'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: Western Texas College's Financial Aid Director will create a report showing students who are receiving grades of "F" or "I" after the 10th week of Instruction. Western Texas College Instructors will submit a list of students who received grades of "F" or "I" and stopped participating in the course to the Director of Counseling and Admissions. The Financial Aid Director will compare students on the 10-week grade report receiving grades of "F" or "I" with the instructor's list of students receiving grades of "F" or "I" and not participating to identify possible R2T4's. These two reports will also be created and compared at the end of each term to identify possible R2T4's.

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS A. Compliance Findings 2019-001 Cluster name: TRIO Cluster CFDA numbers and names: 84.042 TRIO ? Student Support Services 84.044 TRIO ? Talent Search 84.047 TRIO ? Upward Bound Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned Costs: Not applicable Criteria: In accordance with 34 Code of Federal Regulations (CFR 646.3, 645.3, and 644.3), participants in the SSS program must be a United States Citizen or national or meet one of several other residency requirements. Also, the College is required by 2 CFR 200.303 to maintain effective internal control over the TRIO Cluster to provide reasonable assurance that it is managing the award in compliance with federal statutes, regulations, and the award terms. Condition: The District did not maintain effective internal control to ensure that all TRIO Cluster Student Support Services (SSS) program participants were eligible. Specifically, for 2 of 14 SSS participants tested, we noted that the District did not obtain or review sufficient documentation to ensure the participant met eligibility requirements. For those students without sufficient eligibility documentation, we could not determine whether the program participants were eligible. Effect: Without sufficient internal controls to determine eligibility including maintaining evidence to provide reasonable assurance that the College sufficiently determined eligibility, there is an increased risk of program benefits being provided to ineligible participants. Cause: The College did not have sufficient internal control policies and procedures in place to ensure and provide evidence that all program participants were eligible. Recommendation: The College should implement internal control policies and procedures to ensure that it adequately reviews and maintains sufficient eligibility documentation for all TRIO cluster program participants. Views of responsible official and planned corrective actions: Western Texas College will now start requiring every student that wishes to participate in the Student Support Service Program to apply for Financial Aid, FASFA. This will be used to verify the student?s eligibility to go along with the initial application that we have them complete. Western Texas College will also create an internal control procedure to be performed periodically for the TRIO cluster.