Vernon College

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 halftime basis for the period for which the loan was intended." Condition: We reviewed a sample of 40 students who received financial aid and had enrollment status changes during the fiscal year. Of the 40 students tested, 27 students did not have timely or proper status changes reported to the NSLDS. 1 of which was never reported for the semester that the student began enrollment. Population and Sample Size: Number Dollars Questioned Cost Population 1,285 $ N/A $ N/A Sample 40 N/A N/A Not in compliance 27 N/A None 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 College changed software systems in fiscal year 2024. Due to this change in systems, enrollment reports submitted to the NSLDS no longer contained any students who had withdrawn. The reports that were submitted showed all withdrawn students as still enrolled until the following semester when they no longer showed up as a current student. The college failed to review the reports prior to submission to the NSLDS to ensure withdrawn students were appropriately caught, resulting in enrollment statuses for students not being reported in a timely manner. Recommendation: We recommend that the college work with Ellucian Colleague, the new software system, to update the system settings to track enrollment changes for students. We recommend management develop a report to generate that can be uploaded to the NSLDS with accurate enrollment statuses, as well as create an internal process of review to ensure that the reports are accurate before they are submitted to the NSLDS.

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 halftime basis for the period for which the loan was intended." Condition: We reviewed a sample of 62 students who received financial aid and had enrollment status changes during the fiscal year. Of the 62 students tested, 24 students did not have timely or proper status changes reported to the NSLDS. 11 of which have not been reported as withdrawn at all. Population and Sample Size: Number Dollars Questioned Cost Population 2,167 $ N/A $ N/A Sample 62 N/A N/A Not in compliance 24 N/A None 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 College changed software systems in fiscal year 2024. Due to this change in systems, enrollment reports submitted to the NSLDS no longer contained any students who had withdrawn. The reports that were submitted showed all withdrawn students as still enrolled until the following semester when they no longer showed up as a current student. The college failed to review the reports prior to submission to the NSLDS to ensure withdrawn students were appropriately caught, resulting in enrollment statuses for students not being reported in a timely manner. Recommendation: We recommend that the college work with Ellucian Colleague, the new software system, to update the system settings to track enrollment changes for students. We recommend management develop a report to generate that can be uploaded to the NSLDS with accurate enrollment statuses, as well as create an internal process of review to ensure that the reports are accurate before they are submitted to the NSLDS.

Criteria: In accordance with CFR sections 34 CFR § 668.164 and 34 CFR § 690.63, "Title IV funds, including Pell Grants, must be disbursed in a manner that aligns with the start of each academic term, ensuring that students have timely access to funds for educational expenses. Institutions are required to handle Pell Grant disbursements promptly to support students’ needs within the academic term. Payments are distributed based on specific payment periods, typically aligned with semesters, quarters, or other designated terms. Funds must be available within the designated academic period to meet the financial needs of students effectively." Condition: We reviewed a sample of 40 students who received financial aid and had enrollment status changes during the fiscal year. Of the 40 students tested, one student did not receive his Pell payment for the Fall 2023 term. The student did not receive his Pell payment until the end of the fall academic period resulting in a missed disbursement on behalf of the student. Disbursement was made later in the same fiscal year during a later term. Population and Sample Size: Number Dollars Questioned Cost Population 1,907 $ N/A $ N/A Sample 40 N/A N/A Not in compliance 1 N/A None Effect: The institution may be required to return funds to the Department of Education. This situation can create financial challenges for the institution and impact students who may no longer have access to those funds. Students may experience financial hardship if Pell Grants or other Title IV funds are not disbursed on time, leading to difficulties in paying tuition, fees, and other educational expenses. Such delays can potentially affect their academic performance or ability to continue their studies. Additionally, if an institution consistently fails to comply with federal regulations, it risks losing its eligibility to participate in federal financial aid programs, severely limiting the financial aid options available to its students. Cause: The college received the student’s 2023-24 ISIR on January 2, 2024, after the end of the fall 2023 semester. The student’s fall aid was not paid out as the payment process at that time was only run for the Spring 2024 semester. The college found that the student’s fall aid did not disburse during the summer of 2024 and disbursed the aid the student was eligible to receive for the fall semester. Recommendation: We recommend that the college create an internal process of review to ensure that financial aid awards are disbursed in the semester that they are awarded.

A. Compliance Findings 2022-001 Program Name: Student Financial Aid Cluster Assistance Listing Numbers/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), 685.309(b), and 690,83(b)(2), "upon receipt of an enrollment report from the Secretary (U.S. Department of Education, Secretary of Education), a school must update all information included in the report and return the report to the Secretary, in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. 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 8 students who withdrew during the fiscal year. Of the 8 students tested, four students were reported to NSLDS after the required 60-day period. The POISE system would not correctly report withdrawn students during the year due to an error in the system. All withdrawn students were appropriately reported as withdrawn at the beginning of the subsequent semester, which often fell outside the 60-day period. Population and Sample Size: Number Dollars Questioned Cost Population 85 $ N/A $ N/A Sample 8 N/A N/A Not in compliance 4 N/A None 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 reporting 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. Due to technical complications in the College's student system, POISE, withdrawn students were not included on the enrollment reports uploaded to the NSLDS every 30 days. Withdrawn students were instead only included on reports that were run once a semester. All four students were not reported to the NSLDS as withdrawn within the required 60-day time limit each of their appropriate semester. One student in the Fall 2021, one student in the Spring 2022, and two students in the Summer 2022. Recommendation: We recommend the College 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.