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«FINAL AUDIT REPORT ED-OIG/A07L0001 February 2014 Our mission is to promote the U.S. Department of Education efficiency, effectiveness, and Office of ...»

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Cost of Attendance Penn State’s cost of attendance budget included tuition and fees and allowances for room and board, books, transportation, and miscellaneous expenses. Penn State created a separate cost of attendance budget that did not include an allowance for transportation costs for distance education students.

Billings and Disbursements Penn State is a term-based school operating on a semester system and charging tuition and fees by the semester. Penn State established the semester as its payment period for Title IV purposes.

Each semester was 15 weeks, and Penn State began a new semester each fall, spring, and summer.

Penn State disbursed loan funds 10 days before the start of each semester. It generally disbursed Pell funds during the first week of each semester. Penn State programmed its higher education software to automatically disburse Title IV funds if the student met all disbursement requirements, such as enrollment in at least 6 credit hours for loans and enrollment as a full-time student for a full-time Pell award. If a student was in default on a loan, the higher education software would not automatically disburse the Title IV funds.

Attendance and Withdrawal Policies Penn State used the same attendance policy for all students, regardless of whether they were enrolled in traditional courses, distance education courses, or both. That policy did not establish what activities could or could not be considered evidence of academic attendance. Instead, faculty members were responsible for determining what activity would be considered evidence of academic attendance. Evidence of academic attendance was maintained in either the online learning management system or outside the online learning management system.

Faculty members also were responsible for determining whether a student (1) began attending a course, (2) stopped attending a course, or (3) completed a course. If assigning a grade of F, the faculty member was required to indicate the reason for the F (partially participated, participated the entire semester, or never participated). If a student stopped attending, the faculty member was given the option to enter the last date of attendance into the online learning management system but was not required to do so. Penn State’s financial aid office would review the records of students who received all F grades in a payment period to determine whether the students unofficially withdrew from the school and needed a return of Title IV aid calculation performed.

Final Audit Report ED-OIG/A07L0001 Page 49 of 83 Penn State was not required to take attendance. However, if a faculty member provided a last date of attendance for a student who unofficially withdrew, then Penn State used the last date of attendance as the student’s withdrawal date for the return of Title IV aid calculation. Otherwise, Penn State used the midpoint of the payment period as the student’s withdrawal date.

Determination of Attendance Affects Compliance With the Title IV Requirements We identified attendance issues that affected Penn State’s compliance with the Title IV requirements in four areas: (1) treatment of Title IV funds when a student withdraws, (2) treatment of Title IV funds when a student does not begin attendance, (3) confirmation of eligibility at the time of disbursement, and (4) recalculation of the Pell award.

Penn State considered a student’s entering an online class via a secure login to be sufficient evidence of academic attendance and aligned with the regulation in effect during the audit period. Penn State stated that the OIG, in making its determination of attendance (see “Methodology for Reviewing Student Records” in Appendix B), applied regulations that were not in effect during the audit period. Specifically, Penn State stated that the OIG applied the definition of attendance in 34 C.F.R. § 668.22(l)(7)(i), which did not become effective until July 1, 2011.

We disagree with Penn State’s position that a student’s entering an online class via a secure login was sufficient evidence of academic attendance during our audit period. Even before July 1, 2011, the regulations required activity supporting attendance to be academically related.

Absent any other evidence of activity, a student’s logging in to an online course is not sufficient to satisfy the regulatory requirement.

Treatment of Title IV Funds When a Student Withdraws Of the 50 students in our sample, 35 withdrew during a payment period. Penn State did not treat Title IV funds properly for 25 of the 35 students who withdrew. For 14 of the 25 students, Penn State used a last date of attendance that was not supported by evidence of the student’s academic attendance. 17 It did not perform return of Title IV aid calculations for 11 students.

Using information recorded in Penn State’s online learning management system and other records, we determined that Penn State did not properly handle Title IV funds for 18 of the 25 students. As a result, Penn State returned $12,814 less than it should have for 8 students and $17,882 more than it should have for 10 students.

Penn State agreed that it improperly handled Title IV funds for 1 student but disagreed with our

conclusion for the other 17 students. Penn State provided the following explanations:

• Ten of the 18 students officially withdrew from school. Penn State performed return of Title IV aid calculations based on the “date of action” recorded in its higher education software. Penn State explained that the “date of action” recorded in the higher education software was the date that the students officially withdrew from

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• Five of the 18 students possibly had academically related contacts with faculty members that were not logged in to the online learning management system.

However, time did not permit Penn State to contact all the faculty members to gather documentation that supported the reported last dates of attendance for each of these five students.

• Two of the 18 students officially and unofficially withdrew from a combination of courses. Penn State performed the return of Title IV aid calculations based on the dates of the last recorded student course activity for these two students. Penn State believed it used the correct dates for both students.

We disagree with Penn State’s position that it used the appropriate withdrawal date for the 10 students who officially withdrew. For those 10 students, the “date of action” recorded in the higher education software as the date the student officially withdrew could not be corroborated with other evidence. The student emails and letters that Penn State provided us and activity reports from the higher education software indicated other dates of withdrawal.

For the remaining seven students, we disagree with Penn State’s position that it used the appropriate withdrawal date. Using information from Penn State’s online learning management system or other records, we concluded that all seven students unofficially withdrew. However, the withdrawal dates that Penn State used for the students were not supported. During our review of students’ records, if we were unable to find support for the withdrawal dates that Penn State used, we asked Penn State to provide evidence to support the dates that it used. In response, Penn State did not provide evidence that supported the withdrawal dates for these seven students.

Treatment of Title IV Funds When a Student Does Not Begin Attending Classes Of the 50 students in our sample, Penn State did not return $27,980 in Title IV funds that it credited to the accounts of or disbursed directly to seven students without evidence of the students’ attendance in academically related activities during the payment period.

Penn State did not provide any evidence to show that the seven students were engaged in academically related activities as required by 34 C.F.R. § 668.22(c)(3).

Confirmation of Eligibility at the Time of Disbursement The records for 21 of the 50 students in our sample indicated that the students received Title IV disbursements after the start of the payment period. Penn State disbursed $55,550 to 8 of the 21 students without evidence of the students’ academic attendance before the disbursements.

Penn State explained that, for students receiving disbursements on or after the first day of classes, nightly automated processes performed all eligibility checks before the release of Title IV funds. The eligibility check verified the student was in a “registered” status. A student is placed in a registered status after registering for classes and taking deliberate action within the Final Audit Report ED-OIG/A07L0001 Page 51 of 83 Web-based student portal to either pay the tuition bill or confirm that all his or her charges will be covered by financial aid. Penn State considered the registered status to be the initial proof of student attendance for Title IV disbursement purposes. Penn State stated that the eight students who received Title IV disbursements after the start of the payment period all had their eligibility status checked, as described; therefore, Penn State concluded that the students were eligible for the disbursements.

We disagree with Penn State’s position. According to guidance from the Department, if a Title IV disbursement occurs on or after the first day of classes, the school must determine whether the student began attending his or her classes before disbursing Title IV funds. If the student did not begin attending classes, the student is not eligible to receive the Title IV disbursement (“2010–2011 Federal Student Aid Handbook,” Volume 4, Chapter 1, page 4-21).

The actions required by a student to be placed in a registered status did not include any academically related activities. Therefore, if the disbursement was made after the first day of classes, Penn State could not use a student’s registered status as the sole evidence of the student’s eligibility for a Title IV disbursement. For disbursements made after the first day of classes, Penn State would need evidence that the student attended an academically related activity before making the disbursement. Penn State’s online learning management system or other records did not show evidence that any of the eight students attended an academically related activity as required by 34 C.F.R. § 668.22(c)(3) during the payment period.

Recalculation of Pell Awards Of the 50 students in our sample, Penn State’s online learning management system records or other records for 8 students indicated a change in enrollment status based on the students’ lack of academic attendance in 1 or more of their classes. The enrollment status changes for all eight students had an effect on the students’ Pell eligibility. As a result, Penn State awarded $4,825 more than it should have awarded to six students and awarded $1,387 less than it should have awarded to two students.

Penn State stated that human error caused the incorrect Pell award calculation for one student.

Penn State informed us that it recently implemented refresher training on how to calculate Title IV awards and how to verify that Title IV award calculations performed manually are correct. For the remaining seven students, Penn State discussed the use of the semester midpoint to perform the recalculations or explained how it performed return of Title IV aid calculations, or both. Penn State did not address the lack of evidence to support the students’ attendance at academically related activities.

Final Audit Report ED-OIG/A07L0001 Page 52 of 83 Appendix D: Kent State University 4-year public school Kent State was established in 1910, and its main campus is located in Kent, Ohio. The school is accredited by The Higher Learning Commission. Kent State offers 12 degree programs and 9 certificate programs entirely through distance education. Kent State also offers 5 degree programs and 4 certificate programs that are a combination of distance education and traditional courses. During award year 2010–2011, Kent State disbursed more than $326 million in Title IV funds to about 31,000 students, including about 900 students who were enrolled solely in distance education courses.

Cost of Attendance Kent State’s cost of attendance budget included tuition and fees and allowances for room and board, transportation, books and supplies, and miscellaneous and personal expenses. Kent State did not create a separate cost of attendance budget for distance education students.

Billings and Disbursements Kent State is a term-based school, operating on a semester system and charging tuition and fees by the semester. Kent State established the semester as its payment period for Title IV purposes.

Each semester was 15 weeks, and Kent State started a new semester each fall, spring, and summer. Although Kent State offered alternative academic periods of 5, 7, or 7.5 weeks, it considered the alternative periods part of the semester because they occurred during the 15-week semester.

Kent State disbursed Title IV funds 10 days before the start of each semester, programming its higher education software to automatically disburse Title IV funds if the student met all disbursement requirements, such as the student completing loan entrance counseling and signing a master promissory note. If a student had defaulted on a loan, exceeded the annual loan limits, or had a social security number that did not match the student’s record in the National Student Loan Data System, the higher education software would not automatically disburse the Title IV funds.

Attendance and Withdrawal Policies Kent State used the same attendance policy for traditional and distance education students. That policy did not establish what activities could or could not be considered evidence of academic attendance. Instead, faculty members were responsible for managing student attendance. The faculty member’s attendance policy for each course was to be written in the course syllabus.

Each faculty member determined what activity would be considered evidence of academic attendance and how he or she would monitor a student’s attendance. Evidence of academic attendance was maintained in either the online learning management system or outside the online learning management system.



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