EIN: 956006586
UEI: L5AQB3GYNQ56
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 11, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 11, 2026 (74 days ago).
What is a management decision? →During testing over the NSLDS reporting requirements, we noted four of twenty-five student certification dates were not within 60 days of the date of change reported on NSLDS. Context: The District disbursed financial aid to approximately 587 students that required student enrollment and program enrollment reporting to NSLDS. A representative selection of twenty-five students were haphazardly selected for testing of compliance requirements. Questioned Costs: None. Cause: Lack of review process to ensure that student certification dates are reported on NSLDS in a timely manner. Effect: The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Recommendation: The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Views of Responsible Officials: The Downey Adult School (DAS) concurs with the audit finding and to prevent future occurrences, the school has purchased a new student database management software system (Campus Café) that articulates with the National Student Loan Data System (NSLDS) in reviewing, updating, verifying, and reporting student enrollment statuses, program information, and effective starting and ending dates that are required to appear on the Enrollment Reporting Roster file, this new process of enrollment and certification eliminated the potential for human errors by obtaining student information data derived directly from the Student Information System (SIS). In addition, DAS continues to work with its SIS, Campus Café, to electronically integrate with the National Clearing House, specifically with direct transmission of enrollment and certification reporting. The current processes of enrollment and certification reporting will be eliminated and replaced with processes of direct enrollment and certification reporting from the SIS to the National Clearing House, then to NSLDS. Implementation Date: August 18, 2025
Show full finding ▾Hide full finding ▴Finding 2025-001: NSLDS Reporting Requirements (50000) This is not a repeat finding. Program Identification: Federal Agency: U.S. Department of Education Program Names: Federal Pell Grant Program (AL No. 84.063) Criteria: OMB Compliance Supplement, OMB No. 1845‐0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During testing over the NSLDS reporting requirements, we noted four of twenty-five student certification dates were not within 60 days of the date of change reported on NSLDS. Context: The District disbursed financial aid to approximately 587 students that required student enrollment and program enrollment reporting to NSLDS. A representative selection of twenty-five students were haphazardly selected for testing of compliance requirements. Questioned Costs: None. Cause: Lack of review process to ensure that student certification dates are reported on NSLDS in a timely manner. Effect: The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Recommendation: The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Views of Responsible Officials: The Downey Adult School (DAS) concurs with the audit finding and to prevent future occurrences, the school has purchased a new student database management software system (Campus Café) that articulates with the National Student Loan Data System (NSLDS) in reviewing, updating, verifying, and reporting student enrollment statuses, program information, and effective starting and ending dates that are required to appear on the Enrollment Reporting Roster file, this new process of enrollment and certification eliminated the potential for human errors by obtaining student information data derived directly from the Student Information System (SIS). In addition, DAS continues to work with its SIS, Campus Café, to electronically integrate with the National Clearing House, specifically with direct transmission of enrollment and certification reporting. The current processes of enrollment and certification reporting will be eliminated and replaced with processes of direct enrollment and certification reporting from the SIS to the National Clearing House, then to NSLDS. Implementation Date: August 18, 2025
The Downey Adult School (DAS) concurs with the audit finding and to prevent future occurences, the school has purchased a new student database management software system (Campus Café) that articulates with the National Student Loan Data System (NSLDS) in reviewing, updating, verifying, and reporting student enrollment statuses, program information, and effective starting and ending dates that are required to appear on the Enrollment Reporting Roster file, this new process of enrollment and certification eliminated the potential for human errors by obtaining student information data derived directly from the Student Information System (SIS). In addition, DAS continues to work with its SIS, Campus Cafe, to electronically integrate with the Nation Clearing House, specifically with direct transmission of enrollment and certification reporting. The current processes of enrollment and certification reporting will be eliminated and replaced with processes of direct enrollment and certification reporting from the SIS to the National Clearing House, then to NSLDS. The contact person responsible for the implementation of this action plan, to correct State Finding 2025-001, is Ms. Blanca Rochin, Downey Adult School Principal. Implementation Date: August 18, 2025
FAC accepted this audit on March 13, 2024 — management decision was due September 13, 2024.
50000 – NSLDS Reporting Requirements Program Name: Federal Pell Program Federal Financial Assistance Listing Numbers: 84.063 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845‐0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: - One of ten students did not have a Program Start Date that matched between the District’s records and the NSLDS Program Screen. - One of ten students did not have updated enrollment status changes reported correctly to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 400 students that required student enrollment and program enrollment reporting to NSLDS. A non-statistical sample of 10 students were haphazardly selected to perform prior year finding follow-up procedures. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report the enrollment information for students under the Pell Grant Program via NSLDS accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Show full finding ▾Hide full finding ▴50000 – NSLDS Reporting Requirements Program Name: Federal Pell Program Federal Financial Assistance Listing Numbers: 84.063 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845‐0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: - One of ten students did not have a Program Start Date that matched between the District’s records and the NSLDS Program Screen. - One of ten students did not have updated enrollment status changes reported correctly to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 400 students that required student enrollment and program enrollment reporting to NSLDS. A non-statistical sample of 10 students were haphazardly selected to perform prior year finding follow-up procedures. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report the enrollment information for students under the Pell Grant Program via NSLDS accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
The Downey Adult School concurs with the finding and to prevent future occurrences, the school purchased a new student database management software system (Campus Café) that was implemented on August 1, 2023. The school also partnered with National Student Clearinghouse (NSCH). NSCH articulates with the new student database management software system (Campus Café). The new student database management software system together with National Student Clearinghouse will help to prevent human errors and omissions from occurring when reporting National Student Loan Data System (NSLDS) data. While the district purchased the new system in November of 2022, the school did not begin using the new system(s) until August of 2023 because the switch had to be implemented at the beginning of the fiscal year. Implementation is a several month process and all DAS employees have been receiving extensive training (ongoing) to be proficient and comfortable with the new system(s). We have ongoing weekly training for all DAS staff as we continue to fully implement the new student database management software system.
2022-001
FAC accepted this audit on February 5, 2023 — management decision was due August 5, 2023.
50000 ? NSLDS Reporting Requirements Program Name: Federal Pell Program Federal Financial Assistance Listing Numbers: 84.063 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: - Two of 60 student certification dates were not within 60 days of the date of change reported on NSLDS. - Four of 60 students did not have program enrollment information reported to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 550 students that required student enrollment and program enrollment reporting to NSLDS. A non-statistical sample of 60 students were haphazardly selected for testing of compliance requirements. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Show full finding ▾Hide full finding ▴50000 ? NSLDS Reporting Requirements Program Name: Federal Pell Program Federal Financial Assistance Listing Numbers: 84.063 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: - Two of 60 student certification dates were not within 60 days of the date of change reported on NSLDS. - Four of 60 students did not have program enrollment information reported to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 550 students that required student enrollment and program enrollment reporting to NSLDS. A non-statistical sample of 60 students were haphazardly selected for testing of compliance requirements. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Corrective Action Plan and Views of Responsible Officials The Downey Adult School concurs with the finding and to prevent future occurrences, the school has purchased a new student database management software system that will articulate with the National Student Loan Data System (NSLDS) in reviewing, updating, verifying and reporting student enrollment statuses, program information, and effective starting and ending dates that are required to appear on the Enrollment Reporting Roster file. The District has also partnered with the National Student Clearinghouse. The National Student Clearinghouse offers no cost services that help institutions meet compliancy, administrative, student access, and accountability needs. The automated reporting capabilities of this new system will prevent human errors and omissions from occurring when reporting NSLDS data. In addition, staff will be specifically trained on how to use the new system to process, review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
FAC accepted this audit on January 14, 2021 — management decision was due July 14, 2021.
SPECIAL TESTS AND PROVISIONS - RETURN TO TITLE IV Program Name: Federal Pell Grant Program CFDA Number: 84.063 Direct funded by U.S. Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Special Tests and Provisions ? Return to Title IV 34 CFR section 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency: The District did not return the funds to ED within the 45-day requirement. Questioned Costs There are no questioned costs associated with this finding. The District did return funds; however, they were not returned within the 45-day requirement. Context Out of 12 records tested, two instances were noted in which the District did not return the Title IV funds within the required 45-day timeframe Effect The District is not in compliance with federal requirements associated with student withdrawals and the Return to Title IV process. Cause The District does have a procedure in place to ensure timely return of funds, however, the District is not adhering to their procedure. Repeat Finding Yes. See prior year finding 2019-002. Recommendation It is recommended that the District follow procedures to ensure that the Title IV funds are returned to ED within the 45-day requirement.
Show full finding ▾Hide full finding ▴SPECIAL TESTS AND PROVISIONS - RETURN TO TITLE IV Program Name: Federal Pell Grant Program CFDA Number: 84.063 Direct funded by U.S. Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Special Tests and Provisions ? Return to Title IV 34 CFR section 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency: The District did not return the funds to ED within the 45-day requirement. Questioned Costs There are no questioned costs associated with this finding. The District did return funds; however, they were not returned within the 45-day requirement. Context Out of 12 records tested, two instances were noted in which the District did not return the Title IV funds within the required 45-day timeframe Effect The District is not in compliance with federal requirements associated with student withdrawals and the Return to Title IV process. Cause The District does have a procedure in place to ensure timely return of funds, however, the District is not adhering to their procedure. Repeat Finding Yes. See prior year finding 2019-002. Recommendation It is recommended that the District follow procedures to ensure that the Title IV funds are returned to ED within the 45-day requirement.
Corrective Action Plan DAS continues to adhere to their Revised R2T4 Policy found on pages 47-51 of the DAS Financial Aid Policies and Procedures Manual. Moreover, DAS has continued to work closely with US Department of Education Program Compliance Review Specialists regarding previous R2T4 findings. Throughout the last 24 months, and as recent as September 2020, DAS?s Financial Aid Team has participated in deep discussions and deeper reviews of our R2T4 procedures. As a result of the Federal Award Findings for the Year Ended June 30, 2020, DAS has added an additional step in their procedures to a student?s withdrawal/dismissal. DAS Financial Aid Department continues to be made aware of a student?s separation from DAS through email communication from either the student?s instructor, Program Director, and/or CTE Program?s Clerical Staff. Financial Aid staff responds to the departments and refers the student file to the Bursar for R2T4/PWD calculations. In an effort to ensure that the student?s R2T4 record is processed in a timely manner, DAS has now implemented a system in which the Financial Aid Clerk provides the Bursar with a weekly (every Friday) ?check-in? email regarding the status of any drops or withdrawal that occurred within that week. Financial Aid Clerk will continue to monitor the student?s file until R2T4 worksheet is prepared, sent to ED and filed within DAS records. Furthermore, DAS has now trained a second staff member to conduct the R2T4 calculations in the absence of the Bursar/Senior Accounting Technician. DAS?s Intermediate Accounting Assistant has been charged with the responsibility to take the lead in the timely calculation and filing of the R2T4 process as needed.
2019-002
FAC accepted this audit on January 8, 2020 — management decision was due July 8, 2020.
REPORTING Program Name: Federal Pell Grant Program CFDA Number: 84.063 Direct funded by U.S. Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Common Originations and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Educations (ED) through the COD System. Schools submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools 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 Significant Deficiency: The student disbursement records per the District's EdExpress System do not agree to the student records reported in COD. Additionally, the District did not report student disbursement data to COD within 30 days of disbursement. Questioned Costs There are no questioned costs associated with this finding. Context Of the 40 students tested, the disbursement date in thirteen student COD records did not match the District's EdExpress system. Additionally, for one of the 40 students tested, the disbursement amount in the student COD record did not match the District's EdExpress system. Of the 40 students tested, twelve instances were noted in which the District did not update COD disbursement dates within 30 days of the disbursement date noted within the District's EdExpress system. Effect The District is not in compliance with federal requirements associated with COD reporting. Cause The District's EdExpress system documented the scheduled disbursement date for students, but the District reported the actual disbursement date to COD. The EdExpress system was not updated for the actual disbursement date. This is the cause for twelve of the above noted exceptions for inaccurate disbursement dates. For the exception noted for inaccurate amounts reported to COD, the District reduced the student's awarded amount based on disbursement records found at another institution. The District updated the disbursement amount in COD; however, the District did not update the EdExpress system. The District does not have a procedure to ensure timely reporting to COD. Repeat Finding: No Recommendation It is recommended that the District develop a procedure to ensure that amounts reported to COD represent actual disbursement dates and are properly reflected within the EdExpress system. Additionally, the District should develop a procedure to ensure timely reporting to COD.
Show full finding ▾Hide full finding ▴REPORTING Program Name: Federal Pell Grant Program CFDA Number: 84.063 Direct funded by U.S. Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Common Originations and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Educations (ED) through the COD System. Schools submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools 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 Significant Deficiency: The student disbursement records per the District's EdExpress System do not agree to the student records reported in COD. Additionally, the District did not report student disbursement data to COD within 30 days of disbursement. Questioned Costs There are no questioned costs associated with this finding. Context Of the 40 students tested, the disbursement date in thirteen student COD records did not match the District's EdExpress system. Additionally, for one of the 40 students tested, the disbursement amount in the student COD record did not match the District's EdExpress system. Of the 40 students tested, twelve instances were noted in which the District did not update COD disbursement dates within 30 days of the disbursement date noted within the District's EdExpress system. Effect The District is not in compliance with federal requirements associated with COD reporting. Cause The District's EdExpress system documented the scheduled disbursement date for students, but the District reported the actual disbursement date to COD. The EdExpress system was not updated for the actual disbursement date. This is the cause for twelve of the above noted exceptions for inaccurate disbursement dates. For the exception noted for inaccurate amounts reported to COD, the District reduced the student's awarded amount based on disbursement records found at another institution. The District updated the disbursement amount in COD; however, the District did not update the EdExpress system. The District does not have a procedure to ensure timely reporting to COD. Repeat Finding: No Recommendation It is recommended that the District develop a procedure to ensure that amounts reported to COD represent actual disbursement dates and are properly reflected within the EdExpress system. Additionally, the District should develop a procedure to ensure timely reporting to COD.
Corrective Action Plan Reason The instances in which student COD records did not match the EdExpress system were a result of students not being eligible to receive their disbursement due to unsatisfactory academic progress. It is the practice of the Bursar to change the disbursement dates on the COD system once the student is deemed eligible for their respective disbursement. Downey Adult School?s (DAS's) Financial Aid (FA) staff was unaware of their ability to go back and update data on the EdExpress system once a student record was "batched" through EdConnect system. Furthermore, ever since its inception of the Title IV program at DAS, staff (past and present) were unaware that records on EdExpress and COD needed to match. Additionally, DAS staff would like to note that during a Program Compliance Review conducted by US Department of Education, the same information was tested for the same award year, and the Federal auditors did not identify this issue as a finding. Prompted by this finding, DAS's Financial Aid staff called the EdExpress Help Line on November 13, 2019, to inquire about the ability to correct records after being batched. The EdExpress representative advised that these records should automatically update via daily imports, labeled "CRWB" Web Reponses files. DAS FA staff inquired about how often and where we would have been receiving such files; the technician instructed them to perform a search of the files in their "Activity Log" found on EdConnect. When the search was performed, the only CRWB file that was ever transmitted to DAS was from the Award Year 2012-2013. Since DAS FA staff have never received said files, the technician advised DAS FA staff to call the COD Help Desk and asked them to turn on the settings that enable receipt of said files. On November 13, 2019, DAS FA staff spoke with COD representative and DAS FA Department and the COD representative enabled DAS FA Department to receive the "CRWB" Web Reponses which will automatically update EdExpress system with any changes made to a student record on COD. The "CRWB" Web Reponses do not back-date previously batched files, therefore, effective November 14, 2019, if the instance arises in which the Bursar modifies student records on COD, EdExpress will be automatically updated to reflect the changes. The Bursar will continue to communicate with the FA Department of any changes that were made to a student record on COD and the Financial Aid Administrator will ensure that EdExpress system matches the information on COD.
SPECIAL TESTS AND PROVISIONS - RETURN TO TITLE IV Program Name: Federal Pell Grant Program CFDA Number: 84.063 Direct funded by U.S. Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements 34 CFR section 668.22(j): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(b)(1): An institution must document a student?s withdrawal date as the last date of academic attendance determined by the institution from its attendance records. Condition Significant Deficiency: The District did not determine the withdrawal date within 30 days of the end of the payment period. Significant Deficiency: The District did not return the funds to ED within the 45-day requirement. Significant Deficiency: The District does not maintain supporting documentation for attendance records. Questioned Costs There are no questioned costs associated with this finding. The District did return funds; however, they were not returned within the 45-day requirement. Context Out of 15 records tested, two instances were noted in which the District did not determine the withdrawal date for the student within 30 days of the end of the payment period. Out of 15 records tested, three instances were noted in which the District did not return the Title IV funds within the required 45-day timeframe. In all of the fifteen instances tested, the District did not have adequate documentation that supports the student "Scheduled Hours to Complete" for purposes of performing Return to Title IV calculations. The number of hours scheduled to complete was given by program personnel; however, these amounts could not be substantiated via official school records. Effect The District is not in compliance with federal requirements associated with student withdrawals and the Return to Title IV process. Cause The District does have a procedure in place to monitor the student withdrawal dates no later than every 30 days; however, the District was not adhering to their procedure. The District does have a procedure in place to ensure timely return of funds, however, the District is not adhering to their procedure. The District does not have attendance records to support student withdrawal dates for the Return to Title IV calculations. Repeat Finding: Yes Recommendation It is recommended that the District follow procedures to ensure that the student withdrawal determinations occur within 30 days from the end of the payment period. It is recommended that the District follow procedures to ensure that the Title IV funds are returned to ED within the 45-day requirement. It is recommended that the District maintain adequate documentation to support student withdrawal dates for purposes of performing Return to Tittle IV calculations.
Show full finding ▾Hide full finding ▴SPECIAL TESTS AND PROVISIONS - RETURN TO TITLE IV Program Name: Federal Pell Grant Program CFDA Number: 84.063 Direct funded by U.S. Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements 34 CFR section 668.22(j): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(b)(1): An institution must document a student?s withdrawal date as the last date of academic attendance determined by the institution from its attendance records. Condition Significant Deficiency: The District did not determine the withdrawal date within 30 days of the end of the payment period. Significant Deficiency: The District did not return the funds to ED within the 45-day requirement. Significant Deficiency: The District does not maintain supporting documentation for attendance records. Questioned Costs There are no questioned costs associated with this finding. The District did return funds; however, they were not returned within the 45-day requirement. Context Out of 15 records tested, two instances were noted in which the District did not determine the withdrawal date for the student within 30 days of the end of the payment period. Out of 15 records tested, three instances were noted in which the District did not return the Title IV funds within the required 45-day timeframe. In all of the fifteen instances tested, the District did not have adequate documentation that supports the student "Scheduled Hours to Complete" for purposes of performing Return to Title IV calculations. The number of hours scheduled to complete was given by program personnel; however, these amounts could not be substantiated via official school records. Effect The District is not in compliance with federal requirements associated with student withdrawals and the Return to Title IV process. Cause The District does have a procedure in place to monitor the student withdrawal dates no later than every 30 days; however, the District was not adhering to their procedure. The District does have a procedure in place to ensure timely return of funds, however, the District is not adhering to their procedure. The District does not have attendance records to support student withdrawal dates for the Return to Title IV calculations. Repeat Finding: Yes Recommendation It is recommended that the District follow procedures to ensure that the student withdrawal determinations occur within 30 days from the end of the payment period. It is recommended that the District follow procedures to ensure that the Title IV funds are returned to ED within the 45-day requirement. It is recommended that the District maintain adequate documentation to support student withdrawal dates for purposes of performing Return to Tittle IV calculations.
Corrective Action Plan It is recommended that the District follow procedures to ensure that the student withdrawal determinations occur within 30 days from the end of the payment period. DAS has adopted the practice of disbursing within the first seven days of each payment period, which requires updated status from the department. This ensures that withdrawn/dropped students are identified within a week of the end of the payment period. It is recommended that the District follow procedures to ensure that the Title IV funds are returned to ED within the 45-day requirement. The student records which were tested were from the 2018-2019 Award Year; DAS has since identified the reason for irregularities and have implemented policies and procedures (see excerpt below) to ensure compliance of the 45-day requirement. It is recommended that the District maintain adequate documentation to support student withdrawal dates for purposes of performing Return to Tittle IV calculations. DAS continues to utilize email communication and attendance records to support the initiation, reporting, and finalizing of a student's withdrawal/drop with regard to R2T4 calculations. Background of US Department of Education's (ED) Program Compliance Review In December of 2018, DAS was contacted by the ED, Federal Student Aid department informing us that we had been selected for a Program Compliance Review. The week of January 14th, a team of three (3) federal auditors visited DAS for four (4) days and conducted a full-scale review of DAS's administration of Federal Student Aid funds, as well as DAS's institutional operations as they pertain to Title IV law. Amongst other findings, ED auditors identified issues with DAS's R2T4 practices and timeliness and accuracy of calculations. ED cited the R2T4 irregularities and delineated them in Finding #5 of the Program Review Response (PRR) which was issued to DAS staff April 2019. DAS was directed to respond to the PRR and provide corrective actions to all findings cited in the PRR. At the request from ED, in addition to modifying institutional and financial aid policies and procedures related to R2T4, DAS FA staff also conducted a recalculation of every R2T4 student record for the Award Years 2017-2018 and 2018-2019. Below are actions taken per recommendations from ED Program Compliance Review: Bursar conducted a full file review to identify all officially or unofficially withdrawn students during both 17/18 and 18/19 award years. For each withdrawn student, DAS performed an R2T4 calculation using the correct LDA based on attendance records and using the correct number of scheduled hours in the payment period. DAS completed and submitted a R2T4 spreadsheet to detail the results of the full file review for each award year. Revised R2T4 Policy found on pages 49-52 of DAS's Financial Aid Policy and Procedures Manual effective March 2019 (excerpt): Return of Title IV Funds (R2T4) Policy Title IV funds are awarded to the student with the understanding that he/she will attend school for the entire payment period for which the assistance is awarded. When a student withdraws from his/her program, he/she may no longer be eligible for the full amount of Title IV funds that he/she was originally scheduled to receive. The Financial Aid Office is required by federal statute to recalculate Federal financial aid by using the R2T4 form found on the www.ifap.ed.gov website. The institution has 45 days from the date the institution determines that the student withdrew to return all unearned funds for which it is responsible. This policy applies to students who withdraw (officially or unofficially) and cease to be enrolled during a payment period or a period of enrollment in which the recipient began attendance. The law specifies that DAS must determine the amount of Title IV aid the student earned as of the student's withdrawal date. In addition, for a clock-hour program, DAS will use scheduled hours to determine the percentage of the period the student completed in the R2T4 calculation process. The Title IV programs at DAS covered by this law are: Federal Pell Grants. The regulations for the Return of Title IV Funds do not dictate an institution's refund policy. When a student withdraws from a program, the requirements for returning Title IV program funds are separate from any refund policy that the school may have in place. Therefore, the student may still owe funds to the school to cover unpaid institutional charges. The institution is required to determine the earned and unearned portions of Title IV aid as of the date the student ceased attendance. The calculation is based on the amount of time the student was "scheduled to be in attendance". For students who withdraw up through the 60 percent point (in each payment period of enrollment), a pro-rata schedule is used to determine the amount of Title IV funds the student has earned at the time of withdrawal. After the 60 percent point in the payment period, a student has earned 100 percent of the Title IV funds he/she was scheduled to receive during the period. The percentage of a payment period is equal to the clock hours scheduled to have been completed (as of the withdrawal date in the period) divided by the total clock hours in the period. A payment period is defined as an equal to half of the academic year (26 weeks, 900 clock hours). For programs less than an academic year, the total weeks and clock hours will be divided into two equal parts, which then becomes that program's payment periods. For programs greater than one academic year, the first 900 hours are divided into two equal payment periods, and the remaining clock hours at this institution will become the final payment period. If the student earned less than the amount disbursed, the DAS is be required to return a portion of the funds. The refund shall be based on Title IV funds that were disbursed or could have been disbursed to a student for the period for which the calculation is being performed for the payment period. The institution must return funds to the following sources, in order, up to the total net amount disbursed from each source: Federal Pell Grant. If the student earned more aid than the amount disbursed to the school to cover institutional charges, a post-withdrawal disbursement must be made within 30 days of the date the institution determined that the student withdrew. The post-withdrawal disbursement will automatically go to the institution to cover any remaining costs related to tuition, books, supplies, and applicable fees. A withdrawal is considered "official" if a written request to withdraw is received by the school via email, fax or in person. A withdrawal is considered "unofficial" if written notification is not received by the school from the student, prior to withdrawal from the program. Determination of Last Date of Attendance Official Withdrawal: DAS will utilize the last date of attendance recorded on ASAP system. DAS shall not consider the LDA as the day in which the notice was received. Unofficial Withdrawal: DAS will utilize the last date of attendance recorded on ASAP system. DAS shall not consider the Date of Determination (DOD) as the LDA. In the instance a student violates their respective CTE program's attendance policy, the CTE department must notify the Financial Aid Department via email no later than ten (10) school days. Leave of Absence: DAS will utilize the last date of attendance recorded on ASAP system. DAS shall not consider the Date of Determination (DOD) as the LDA. Procedure DAS will utilize the Last Date of Attendance (LDA) as a student's withdrawal date. Upon notification from the CTE program's clerk, the FAA will provide the Bursar with a directive to proceed with R2T4/PWD calculation via email. 1. Email will delineate the following information: a. Start Date. b. LDA. c. Scheduled number of hours per pay period. d. Total number of hours attended. Bursar Responsibilities: 1. Bursar will confirm the LDA on the ASAP system. 2. Performs a "Return of Title IV Funds" calculation. 3. If applicable, refunds and/or post-withdrawal disbursements are made. 4. The school then applies the school's internal refund policy. 5. The student is provided with or mailed/emailed the student's "Charges for Withdrawal" stating tuition, books and fees incurred while attending the institution. a. This includes monies/funds received from all sources and monies/funds returned to all sources. b. The final charges upon withdrawal determine whether the student may owe the school money. The school's "refund policy" is also consulted with and noted.
2018-001
FAC accepted this audit on January 2, 2019 — management decision was due July 2, 2019.
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