Compliance Findings & Resolutions, Part 2 of 3

By Sherri Savasta

In our previous blog, we provided the first three solutions offered by Global Consulting to assist institutions reeling from 10 common results of an audit or a Department of Education program review. In this blog today, we will cover the next three findings.

First, we will provide a brief recap.

Since 1996, Global Financial Aid Services has provided consulting support in resolving compliance findings. Our team members bring years of experience to our solutions and familiarity with all aid delivery options for all size institutions.

Below are some of the most recently released audit determinations and program review findings and following are details about how Global Consulting can lend valuable assistance to your financial aid team for findings 4-6. Please see our October 17 blog on how we can assist with findings 1-3.

Common fiscal year 2023 audit determination and program review findings include:

1. Student Status Reporting is Inaccurate or Untimely

2. R2T4 Calculation Errors

3. R2T4 Funds Made Late

4. Entrance/Exit Counseling Deficiencies

5. Lack of Administrative Capabilities

6. Consumer Information Requirements Not Met

7. Verification or C-Flag Violations

8. Crime Awareness Requirements Not Met

9. Clock to Credit Hour Conversion

10.  Awarding/Disbursement Errors

Financial aid administrators can download a complete list of final audit determinations and the department’s final program review findings for fiscal year 2023 here.

In this blog, we will review the next three findings and Global’s support offerings.

4. Entrance/Exit Counseling Deficiencies

Finding Detail – An institution must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower before making the first disbursement of loan proceeds to a student borrower, unless the student borrower has received a prior Direct Subsidized, Direct Unsubsidized, Federal Stafford or Federal SLS Loan. Also, exit loan counseling must be completed by borrowers upon graduating, withdrawing from school or dropping below half-time enrollment. Findings under this heading could be related to the entrance/exit counseling provided not meeting the required language set forth by the department. If your institution is cited for this finding, resolution may require the institution to provide counseling materials to the affected students. If multiple instances of the same error are cited, the institution may need to conduct a file review of all similarly situated students to determine the extent of the error.

Global Offering – Global can evaluate and develop the material for your institution. A reconstruction, including the creation and delivery of the required entrance or exit counseling, is also an option.

5. Lack of Administrative Capabilities

Finding Detail – An institution must demonstrate to the the department that the institution is capable of adequately administering their approved participation in Title IV programs. This includes myriad requirements, such as:

• Designating a capable individual to be responsible for administering all Title IV, HEA programs and for coordinating those programs with the institution's other federal and non-federal programs of student financial assistance.
• Using an adequate number of qualified persons to administer the Title IV, HEA programs in which the institution participates.
• Communicating to the individual designated to be responsible for administering Title IV, HEA programs all the information received by any institutional office that bears on a student's eligibility for Title IV, HEA program assistance.
• Having written procedures for or written information indicating the responsibilities of the various offices with respect to the approval, disbursement and delivery of Title IV, HEA program assistance and the preparation and submission of reports to the Department of Education.

Global Offering – Global can evaluate deficiencies and develop policy, procedures or training to improve the areas lacking.

6. Consumer Information Requirements Not Met

Finding Detail – Institutions are required to provide their students and prospective students with specific consumer information so that students can make informed decisions about their own educational goals, costs and other requirements.

Global Offering – Global can evaluate those deficiencies related directly to financial aid and develop policy, procedures or training to improve the areas lacking.

Please look for our final blog on other compliance findings and Global’s Consulting service offerings.

For assistance, contact Sherri Savasta at (228) 523-1072, ssavasta@globalfas.com or https://globalfas.com/contact.

Sherri Savasta is Global’s Director of Consulting. She has been with Global since 2006, bringing in-depth experience to financial aid processing solutions.