Oregon College of Oriental MedicineNon-Profit

Finding 2024-002 Student Financial Assistance Cluster of Programs Reporting 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 685.304(b)(2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a studyabroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. 34 CFR 685.304(b)(3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 CFR 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: (i) 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: A sample of thirty-seven students was selected for student file and account testing. Two students’ exit counseling was not provided. This is a repeat of prior year Finding 2023-004. Context: This was discovered during the audit testing of student files and accounts. Effect: Withdrawn students did not receive exit counseling for their direct loans in a timely manner. Cause: There appeared to be communication issues between the financial aid department and the other departments of the College. The Director of Financial Aid did not know the students had withdrawn until the audit. Recommendation: As the College has withdrawn from the Title IV program, no further recommendations are deemed necessary. Views of responsible officials: We are in agreement with this finding. Since the closure of the College will result in no further student loan activity, no immediate corrective action is considered necessary.

Finding 2024-003 Student Financial Assistance Cluster of Programs Special Tests and Provisions 84.033 Federal Work-Study Program U.S. Department of Education Criteria: 34 CFR 675.19(b)(1) An institution must follow the record retention and examination provisions in this part and in 34 CFR 668.24. 34 CFR 675.19(b)(2) The institution must also establish and maintain program and fiscal records that: (i) Include a certification by the student's supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day; (ii) Include a payroll voucher containing sufficient information to support all payroll disbursements; (iii) Include a noncash contribution record to document any payment of the institution's share of the student's earnings in the form of services and equipment (see § 675.27(a)); and (iv) Are reconciled at least monthly. Condition: A sample of thirty-seven students was selected for student file and account testing. Of those tested, thirteen earned federal work study wages during the audit period. For two of these students, the College was able to provide approved timesheets, payroll vouchers, and employment files, but was unable to locate documentation substantiating employment eligibility verification under the federal work study program. This is a repeat of prior year Finding 2023-005. Context: This was discovered during the audit testing of federal work study. Effect: The College did not have documented employment eligibility verification for federal work study students. Cause: These appeared to be isolated incidents during a time where payroll management was moved to a new department at the College.

Cash Management Student Financial Assistance Cluster of Programs 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 668.162 (b)(3) The institution must disburse the Title IV funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition: A sample of thirty-seven students was selected for student file and account testing. Two students had their direct loan funds applied to their account four business days after they were drawn down from G5. When the drawdowns and disbursements were examined, it was noted that a total of sixteen disbursements for a total of $128,161 were applied to student accounts after four business days. This is a repeat of prior year Finding 2022-001. Context: This was discovered during the audit testing of student files and accounts. Effect: Because the loans were unsubsidized and PLUS loans, the effect of this issue to the students would be in the form of interest accrued prior to the students having access to the funds. However, due to the COVID-19 pandemic, interest accruals on loans had been suspended and, as such, no interest was accrued during this period. Cause: The late disbursements happened on the same day and appear to be an isolated incident. These amounts appear to have been drawn a day earlier than the ordinary disbursement timeline. Recommendation: We recommend the College improve internal documentation review of Title IV drawdowns to ensure timely application of funds to student accounts. tion 3 - Federal Award Findings and Questioned Costs - Continued Views of responsible officials: As the finding mentioned, this issue was found in the previous audit and corrective action was taken at that time. The finding was the result of human error where draw down dates were not updated from the prior year. Review of the form was expanded to include three members of the Finance Team. No further insances have occurred since.

Reporting Student Financial Assistance Cluster of Programs 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 685.301(a)(1) A school participating in the Direct Loan Program must ensure that any information it provides to the Secretary in connection with loan origination is complete and accurate. 34 CFR 685.301(a)(2) A school must provide to the Secretary borrower information that includes but is not limited to - (i) The borrower’s eligibility for a loan, as determined in accordance with § 685.200 and § 685.203; (ii) The student’s loan amount; and (iii) The anticipated and actual disbursement date or dates and disbursement amounts of the loan proceeds, as determined in accordance with § 685.303(d). Condition: A sample of thirty-seven students was selected for student file and account testing. One of the student’s Fall 2023 PLUS loan disbursement date was incorrectly reported on the Common Origination and Disbursement (COD) website. Context: This was discovered during the audit testing of student files and accounts. Effect: The disbursement date was incorrect in COD for this student, but later corrected. During the uncorrected period, the dates of disbursement in COD did not match NSLDS. Cause: This appeared to be an isolated incident where the disbursement was processed, cancelled, and then reprocessed at a later date for the student requesting an additional PLUS loan. Recommendation: We recommend that the College update their internal documentation review of Title IV reporting to prevent inaccurate reporting dates. Specifically, we recommend including a process where management reviews information for any loans cancelled and re-entered to ensure all information is reported accurately. Section 3 - Federal Award Findings and Questioned Costs - Continued Views of responsible officials: This issue occurred while the Director of Financial Aid was out of the office on Leave. This issue was caused by an issue in Populi’s system and a replacement Financial Aid Officer did not know who was supposed to be included in the disbursement batch. The process will be updated so that a list of all students who are meant to be in a batch will be listed on a report as their requests come in, then the report will be referenced when creating a disbursement batch to make sure no students are missing.

Reporting Student Financial Assistance Cluster of Programs 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 685.304(b)(2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. 34 CFR 685.304(b)(3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. 34 CFR 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 - (i) 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; Section 3 - Federal Award Findings and Questioned Costs - Continued Condition: All students who withdrew from the College during the fiscal year were selected for testing (twenty total students withdrawn). Five students’ exit counseling and/or attendance status were not addressed timely. Context: This was discovered during the audit testing of Return of Title IV. Effect: Withdrawn students did not receive exit counseling for their direct loans in a timely manner. Late updating of NSLDS results in delays in the repayment of the loans. Cause: There appeared to be communication issues between the financial aid department and the other departments of the College. The Director of Financial Aid did not know the students had withdrawn until the audit. Recommendation: We recommend that the College review their internal process regarding timely communication of student withdraws. Views of responsible officials: This issue occurred due to communication issues between departments of the college. The withdrawal process will be reviewed with the Director of Financial Aid, Director of Student and Alumni Affairs, and the Dean of Research and Postgraduate Studies so that all departments understand the deadlines and what the Financial Aid Office needs in order to complete the withdrawal process in a timely manner.

Special Tests and Provision Student Financial Assistance Cluster of Programs 84.033 Federal Work-Study Program U.S. Department of Education Criteria: 34 CFR 675.19(b)(1) An institution must follow the record retention and examination provisions in this part and in 34 CFR 668.24. 34 CFR 675.19(b)(2) The institution must also establish and maintain program and fiscal records that - (i) Include a certification by the student's supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day; (ii) Include a payroll voucher containing sufficient information to support all payroll disbursements; (iii) Include a noncash contribution record to document any payment of the institution's share of the student's earnings in the form of services and equipment (see § 675.27(a)); and (iv) Are reconciled at least monthly. Condition: A sample of thirty-seven students was selected for student file and account testing. Of those tested, nine earned federal work study wages during the audit period. For two of these students, the College was able to provide approved timesheets and payroll vouchers but was unable to locate employment files including documentation substantiating existence, eligibility, and agreement of employment under the federal work study program. Context: This was discovered during the audit testing of federal work study. Effect: The College did not have documented employment files demonstrating existence, eligibility, and agreement of employment for federal work study students. Cause: These appeared to be isolated incidents during a time where payroll management was moved to a new department at the College. Recommendation: We recommend that the College update their internal documentation process to ensure all students hired have complete student employment files. Views of responsible officials: This issue occurred as employee files and onboarding were managed by the Human Resources department, which had also been running payroll. The matter has since been resolved as the accounting department reassumed responsibility for running payroll and is serving as a cross check to ensure that all necessary documentation has been verified as collected by the Human Resources department at the time of onboarding. The responsibility of the Human Resources department remains to ensure that all employee onboarding files are available for review while accounting as the payroll processor shall confirm that student work study hours have been documented and approved by the appropriate supervisor.

Special Tests and Provisions Student Financial Assistance Cluster of Programs 84.033 Federal Work-Study Program U.S. Department of Education Criteria: 34 CFR 675.20(d)(2) A student employed in an FWS job and receiving academic credit for that job may not be - (i) Paid less than he or she would be if no academic credit were received; (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting; and (iii) Paid unless the employer would normally pay the person for the same position. Condition: A sample of thirty-seven students was selected for student file and account testing. Of those tested, nine earned federal work study wages during the audit period. Three of these students tested earned federal work study wages during class hours. Context: This was discovered during the audit testing of federal work study. Effect: The students may have been allowed to earn federal work study wages during class hours. Cause: Management does not have a process to monitor whether students are earning federal work study wages during class hours. Recommendation: We recommend that the College design a process where supervisors of federal work study students where they can ensure they do not earn wages during class hours. Absent that, we recommend management require students to sign an affirmation they will not work during class hours. Views of responsible officials: To make sure this issue does not occur again, we will include an affirmation from all work-study students stating that they will not work during class hours.

Special Tests and Provisions Student Financial Assistance Cluster of Programs 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 668.22(g)(2) - Institutional charges are tuition, fees, room and board, and other educationally-related expenses assessed by the institution. Condition: All Return of Title IV calculations for the year were selected for testing (three total returns). One of the returns included the incorrect amount of tuition charges. Context: This was discovered during the audit testing of Return of Title IV. Effect: The College should not have returned $81 of direct federal loans. Cause: The student changed enrollment status before withdrawing and the tuition charge changes were not initially calculated correctly. Recommendation: We recommend that the College consider augmenting its review process to have the reviewer independently calculate the Return of Title IV funds and compare it to the original calculation. Views of responsible officials: To make sure this issue does not occur again, the Director of Financial Aid will include a printout of the institutional charges at the time of the withdrawal to show what the amounts were during the R2T4 calculations.

Finding 2022-001 Student Financial Assistance Cluster of Programs Cash Management 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 668.162 (b)(3) The institution must disburse the Title IV funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition: A sample of thirty-seven students was selected for student file and account testing. Two students had their direct loan funds applied to their account four business days after they were drawn down from G5. When the drawdowns and disbursements were examined, it was noted that a total of sixteen disbursements for a total of $128,161 were applied to student accounts after four business days. Context: The deficiency was discovered during the audit testing of student files and accounts. Effect: Because the loans were unsubsidized and PLUS loans, the effect of this issue to the students would be in the form of interest accrued prior to the students having access to the funds. However, due to the COVID-19 pandemic, interest accruals on loans had been suspended and, as such, no interest was accrued during this period. Cause: These appeared to be isolated incidents where the balance was drawn a day earlier than other similar disbursement cycles. Recommendation: We recommend that the College update their internal documentation review of Title IV drawdown funds in order to prevent early draws. Views of responsible officials: We concur with this finding. This finding was due to human error. The spreadsheet was copied from the last year, and dates were updated to be the current year. The past year may have had a holiday which caused the G5 funds to be received an additional day before the disbursement date. When updating the dates to the current year, the four-day period was not caught. The form was only reviewed by the Director of Financial Aid. To prevent this error from occurring in the future, three members of the Finance Team will review the disbursement schedule so that there are always multiple personnel reviewing the dates. These three members will include the Director of Financial Aid, and any two of the following: Accounting Manager, Staff Accountant, Registrar, or Business Office and Bookstore Manager.

Finding 2021-001 Student Financial Assistance Cluster of Programs Special Tests and Provisions 84.268 Federal Direct Loan Program U.S. Department of Education Criteria: 34 CFR 668.164(h)(2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: A sample of 37 student accounts were selected for testing. One of the students had a credit balance refund on their account of $1,694 that was remitted 100 days after the initial credit balance was created. Context: The deficiency was discovered during the audit testing of student files and accounts. Effect: The College should have returned the $1,694 within 14 days of when the credit balance refund was created. Cause: This appeared to be an isolated incident where the balance was created without anyone being aware of it and was settled when the student?s aid for the next term was applied to the account. Recommendation: We recommend that the College institute a system that monitors student accounts for credit balances and notifies the financial aid and business offices to ensure Title IV credit balances are paid out timely.Views of responsible officials: We concur with this finding. This finding was due to human error. Due to the student being the last name alphabetically on the list, they were missed in generating the refund report. To prevent this error from occurring in the future, the accounting specialist will compare the Populi batch to the refund report. Accounting will also run a student balance report showing the account balances in Populi to make sure no refunds are being missed.

Finding 2021-002 Higher Education Emergency Relief Fund Reporting 84.425F COVID-19: Institutional Portion U.S. Department of Education Criteria: Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees (Document Citation 85 FR 53802, August 31, 2020): This revised EA, in conjunction with approved information collection under OMB control number 1801-0005, requires grantees receiving awards under Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116-136, 134 Stat. 281 (March 27, 2020), to publicly post certain grant information on the institution's primary website as part of the reporting requirements under Section 18004(e) of the CARES Act. This information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30) thereafter. Condition: Reports for two of four quarters during the fiscal year were reviewed for accuracy and timeliness of posting on the College?s website. The report for quarter one of 2021 was submitted and posted in July 2021. Context: The deficiency was discovered during the audit testing of HEERF reporting.Effect: The College made information about their HEERF Institutional Aid available to the public three months after it was supposed to be posted to their website. Cause: The College hadn?t spent any of their awarded HEERF Institutional Aid during the period in question. The program was still fairly new to the College, and they were getting used to the reporting requirements. This appeared to have been missed, but later quarters were posted correctly. Recommendation: We recommend that the College set calendar reminders and review reporting requirements among the affected departments to ensure the reporting deadlines are not missed. We also recommend the College select one person to be responsible to ensure all reporting for HEERF is done accurately and timely. Views of responsible officials: We concur with this finding. This finding was due to human error and was the result of a transition in staff during the reporting period as it was normally managed by the Annual Giving Director. Although the report had no expenses for the period, it was the first and only instance of missing a reporting deadline for the noted grant as all subsequent reports for HEERF were filed timely including all quarterly and annual reports. Subsequent to this error, the issue has since been resolved as the Director of Financial Aid, CFO, and President review the deadlines for grant reporting on an ongoing basis.

Criteria: 34 CFR 668.22(a)(1) - 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. 34 CFR 668.22(j)(1) An institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition: All Return of Title IV calculations for the year were selected for testing (three total returns). One of the calculations used the incorrect withdrawal date. The error resulted in the College returning $56 less to the Department of Education than they should have. Context: The deficiency was discovered during the audit testing of Return of Title IV. Effect: The College should have returned the additional $56 of unsubsidized loan funds. Cause: There was confusion over what date the student last attended an academically related activity. This appears to be an isolated incident. Recommendation: We recommend that the College consider instituting a system of review for return calculations to ensure any errors are caught before remittance. Views of responsible officials: Per review of the file and correspondence, it was determined the student?s last date of attendance was 10/11/2019, but the R2T4 calculation was done using 10/12/2019 as the last date of attendance incorrectly. We corrected the calculation and returned the correct amount of funds to the federal loan program. We agree with the finding and a course of action was completed to address this finding. To prevent future errors, the college has set up a process where the financial aid coordinator will review the director?s entries and calculations prior to finalizing the R2T4 calculations so errors in date entries can be caught.

Criteria: 34 CFR 685.304(b)(3) - If a student borrower withdraws from school without the schools prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrowers last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: All students who withdrew during the award year were selected for testing (12 total students). We were unable to obtain any evidence that the College had provided one of the students with exit counseling materials within 30 days of the student?s withdrawal. Email communication showed there had been verbal discussions, but the Director of Financial Aid determined no instructions or documentation had been provided until after the 30 day limit. Context: The deficiency was discovered during the audit testing of Return of Title IV. Effect: The student was not provided with written instructions regarding how to complete the direct loan exit counseling within 30 days of their withdrawal. Cause: There was transition in the financial aid department during this time and this part of the withdrawal process was missed. Recommendation: We recommend that the College consider adding a specific step regarding exit counseling to their financial aid wraps and withdrawal checklists to ensure this step is not missed. Views of Responsible Officials: In April 2019, a student withdrew from the college and the college did not provide the federal student loan exit counseling to the student within the 30 days required. There had been verbal discussion about the requirement with the student, but the exit materials and information was not sent to the student within the 30 day limit. The student was later sent the information and completed the exit counseling. We agree with the finding and a course of action was completed to address this finding. To address this finding, the director and the financial aid assistant completed additional training on the withdrawal process. Additionally, the financial aid staff created a manual to address the financial aid process including the withdrawal procedures and expanded the checklist to address the concerns mentioned in this finding. Not only was the manual developed, but it was implemented and automated to be completed online so departments don't have to wait for paper and manual based processes.

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