«FINAL AUDIT REPORT ED-OIG/A07L0001 February 2014 Our mission is to promote the U.S. Department of Education efficiency, effectiveness, and Office of ...»
We received responses and reviewed information from five States: Arizona, Pennsylvania, South Dakota, Utah, and Virginia.
Schools For this audit, we selected eight schools that offered distance education (see Table 5) from the universe of schools that received Pell funds during award year 2009–2010. If a school received only loan funds, we did not include it in our universe. We judgmentally selected two schools from each of four categories: 4-year public, 2-year public, private nonprofit, and proprietary.
The total amount of funding received by the schools in the universes for each category was as follows: 16 • 4-year public: 78 schools that each received more than $130 million in total Title IV funding for award year 2009–2010.
• 2-year public: 81 schools that each received more than $35 million in total Title IV funding for award year 2009–2010.
• Private nonprofit: 74 schools that each received more than $70 million in Title IV funding for award year 2009–2010.
In making our judgmental selections, we considered the amount of Title IV funds that the school received; recent growth in the amount of Title IV funds that each school received; each school’s primary accrediting agency, student retention rates, and default rates; our knowledge of the schools; recent OIG investigations; and recent FSA program reviews.
At each school, we interviewed officials and reviewed handbooks, manuals, and written policies and procedures to gain an understanding of each school’s system of internal control over administration of the Title IV programs as they relate to distance education in the following
We also determined whether the characteristics of each school’s distance education courses were consistent with the definition of distance education or the definition of a correspondence course at 34 C.F.R. § 600.2. In addition, we obtained cost of attendance budgets and data used to support the cost categories to determine whether the school (1) used different cost of attendance budgets for different modes of delivery (such as residential programs, 100-percent distance education programs, correspondence programs, or a hybrid program) and (2) included costs in their cost of attendance budgets that were potentially unnecessary or unreasonable for distance education.
At each school, we randomly selected 50 students from the universe of students who were enrolled solely in distance education courses, received Title IV aid, and did not earn any credits during a payment period that began and ended during the period from July 1, 2010, through June 30, 2011 (see Table 6). We reviewed academic and financial records to (1) determine whether the school complied with selected regulations governing Pell award recalculations, disbursements, return of Title IV aid, and credit balances; (2) determine whether students were potentially straw students; and (3) evaluate whether the school properly determined and adequately documented students’ attendance at academically related activities.
When we finished reviewing the records of 50 students at each school, we provided the school with our results and asked for comments and any additional documentation that might not have been available at the time of our review. If the school provided additional documentation with its comments, we revised our results if the additional documentation was sufficient to demonstrate compliance with the regulatory requirement. The final results of our review of each school and each school’s comments on our results are included as Appendices C through J.
Data Reliability To achieve our objectives, we relied on computer-processed data that each school provided. For each school, the data included students who were enrolled solely in distance education courses, received Title IV aid, and did not earn any credits during a payment period that began and ended during the period July 1, 2010, through June 30, 2011, as well as the amount of Title IV aid disbursed to each student. To test the reliability of the data, we performed tests to look for missing data, the relationship of one data element to another, values outside of a designated range, and dates outside of a designated range. Based on our tests, we determined the data that the schools provided were sufficiently reliable for the purposes of our audit.
We conducted our audit from January 2011 through September 2012. We discussed the results of our work with Department officials on May 3, 2012, and August 27, 2013. We provided a draft of this report to the Department for comment on September 9, 2013. The Department provided comments to the draft report on November 18, 2013.
We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
Final Audit Report ED-OIG/A07L0001 Page 45 of 83 Appendix A: OIG Issued Reports on Audits of Schools Offering Distance Education Programs The following reports provide the results of recent OIG audits covering the distance education environment.
1. “Colorado Technical University’s Administration of Title IV, Higher Education Act Student Financial Assistance Programs,” September 2012 (A09K0008) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2012/a09k0008.pdf 2. “Metropolitan Community College’s Administration of the Title IV Programs,” May 2012 (A07K0003) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2012/a07k0003.pdf 3. “Saint Mary-of-the-Woods College’s Administration of the Title IV Programs,” March 2012 (A05K0012) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2012/a05k0012.pdf 4. “Ashford University’s Administration of the Title IV, Higher Education Act Programs,” January 2011 (A05I0014) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2011/a05i0014.pdf 5. “Baker College’s Compliance with Selected Provisions of the Higher Education Act of 1965 and Corresponding Regulations,” August 2010 (A05I0012) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2010/a05i0012.pdf 6. “TUI University’s Administration of Higher Education Act, Title IV Student Financial Assistance Programs,” August 2009 (A09I0009) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2009/a09i0009.pdf 7. “Walden University’s Compliance with Selected Regulations and U.S. Department of Education Guidance,” January 2009 (A05H0018) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2009/a05h0018.pdf 8. “Capella University’s Compliance with Selected Provisions of the Higher Education Act of 1965 and Corresponding Regulations,” March 2008 (A05G0017) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2008/a05g0017.pdf 9. “Herzing College-Madison’s Compliance with Selected Provisions of the Higher Education Act of 1965 and Corresponding Regulations,” January 2008 (A05H0015) http://www2.ed.gov/about/offices/list/oig/auditreports/fy2008/a05h0015.pdf
Appendix B: Introduction of Information on Selected Schools As part of this audit, we selected eight schools that offered distance education (see Table 5, “Classification of Schools Reviewed”). We judgmentally selected two schools from each of the following four categories: 4-year public, 2-year public, private nonprofit, and proprietary. The information that we are providing in Appendix B is applicable to each of the eight schools discussed in Appendices C through J.
Appendices C through J include general background information on each of the eight schools that we reviewed as part of this audit. In addition, the appendices include information regarding each school’s cost of attendance budgets, billing and disbursement policies, and attendance and withdrawal policies. Finally, the appendices describe instances of noncompliance relevant to the Title IV requirements that we identified during our review, comments that we received from each school regarding the instances of noncompliance, and our analysis of each school’s comments on the issues.
Universes of Students and Sample Selections Each of the eight schools provided us with a universe of students who (1) received Title IV funds, (2) attempted but did not earn any credits, and (3) were enrolled only in distance education courses for payment periods that began and ended during the period July 1, 2010, through June 30, 2011. From each universe, we randomly selected 50 students (see Table 6, “Number of Students in Universe and Sample”).
Methodology for Reviewing Student Records For each sample of 50 students, we obtained data from each school’s online learning management system. We reviewed the data for evidence of attendance consistent with the requirements in 34 C.F.R. § 668.22(c)(3) and in effect during our audit period or any other evidence that might reasonably indicate that a student attended an academically related activity.
We accepted as sufficient evidence of academic attendance a student (1) submitting discussion postings related to the classwork; (2) completing exams, quizzes, or assignments; or (3) initiating contact with a faculty member to ask a question about the academic subject. We did not accept as sufficient evidence of academic attendance a student’s simply logging in to a course when the record of access did not indicate whether the student attended an academically related activity, such as replaying a video lecture, joining an online discussion, or reviewing reading materials.
In the situations described in Appendices C through J, the login record generally did not indicate any activity other than the login itself. We also did not accept discussion postings that were not academically related to be sufficient evidence of academic attendance.
Four of the eight schools whose records we reviewed maintained records outside the online learning management system that could have contained evidence of academic attendance. For those four schools, we first reviewed the records maintained in the online learning management system. If the records in the online learning management system did not provide sufficient evidence of academic attendance, we asked the school for records of academic attendance maintained outside the online learning management system.
Final Audit Report ED-OIG/A07L0001 Page 47 of 83 Criteria Relevant to Issues Identified If a school does not properly determine whether a student attended or remained in attendance and does not retain evidence of such attendance in accordance with Federal regulations, it (1) cannot identify students who withdrew without notification or properly calculate the amount of Title IV funds the student earned before withdrawing, (2) cannot properly identify and return Title IV funds disbursed to students who do not attend during the payment period, (3) cannot determine student eligibility to receive Title IV funds during a payment period, and (4) cannot recalculate Pell awards as required. The following criteria address each of the four areas.
Treatment of Title IV Funds When a Student Withdraws When a student receives Title IV funds and withdraws from a school during a payment period in which the student began attendance, the school must determine the amount of Title IV funds the student earned as of the student’s withdrawal date (34 C.F.R. § 668.22(a)(1)). For schools that are required to take attendance, the student’s withdrawal date is the last date of academic attendance (34 C.F.R. § 668.22(b)(1)). If a school is not required to take attendance and a student withdraws from the school without notification, the school generally may use one of two dates as the student’s withdrawal date: the midpoint of the payment period or period of enrollment, or, with proper documentation, the student’s last date of academic attendance. If the school chooses to consider the withdrawal date as the student’s last date of academic attendance, the school must maintain evidence that the (1) activity is academically related and (2) student attended the academically related activity (34 C.F.R. §§ 668.22(c)(1)(iii) and 668.22(c)(3)).
Treatment of Title IV Funds When a Student Does Not Begin Attendance According to 34 C.F.R. § 668.21(a), if a student does not begin attendance in a payment period or period of enrollment, the school must return all Title IV funds that were credited to the student’s account or disbursed directly to the student for the payment period or period of enrollment.
Confirmation of Eligibility at Time of Disbursements According to Department guidance, 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 to the student. If the student did not begin attending classes, the student is not eligible to receive the Title IV disbursements (“2010–2011 Federal Student Aid Handbook,” Volume 4, Chapter 1, page 4-21).
Recalculation of Pell Award A student’s Pell award is based, in part, on the student’s enrollment status (34 C.F.R.
§§ 690.63(b), 690.
63(c), and 690.63(d)). If a student’s projected enrollment status changes before the student begins attending all of his or her classes for that payment period, the school must recalculate the student’s enrollment status to reflect only those classes for which the student actually began attending classes (34 C.F.R. § 690.80(b)(2)(ii)).
Final Audit Report ED-OIG/A07L0001 Page 48 of 83 Appendix C: The Pennsylvania State University 4-year public school Penn State was established in 1855, and its main campus is located in University Park, Pennsylvania. The school is accredited by the Middle States Commission on Higher Education.
Penn State offers about 70 degree programs and 740 individual courses through distance education. During award year 2010–2011, Penn State disbursed more than $676 million in Title IV funds to about 55,000 students, including about 3,200 students who were enrolled solely in distance education courses.