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4.7 Title IV Program Responsibilities PDF Print E-mail
Thursday, 03 September 2009 13:30

4.7 Title IV Program Responsibilities

The institution is in compliance with its program responsibilities under Title IV of the 1998 Higher Education Amendments.

Responsible Unit: Division of Academic Affairs/Financial Aid

Compliance Judgment



North Carolina Agricultural and Technical State University (A&T) is in compliance with Title IV federal financial aid programs and has been recertified to participate in Title IV. A complete copy of the "Fiscal Operations Report and Application to Participate" (FISAP) validation and application submission is on file in the Student Financial Aid Office and Division of Business & Finance [1].

The Student Financial Aid Office monitors compliance with Title IV programs by reviewing files that are selected for verification by the federal government, or the university. The files are reviewed twice by separate financial aid counselors to ensure compliance. A completed audit sheet [2] is placed in each of the selected student's files. Any discrepancies are identified and corrected [3] [4]. The Treasurer's Office is notified when aid is canceled. Financial aid staff members, who conduct the reviews, have annual training sessions, using publications from the U.S. Department of Education [5] [6] and the university's Banner guide [7]. They are thoroughly familiar with the federal and state regulations.

As part of the Statewide Single Audit, the North Carolina Office of the State Auditor (OSA) is responsible for conducting annual financial aid and federal audits of state agencies and higher education institutions to assure that the State complies with legislation and federal grant requirements that require it to obtain an opinion regarding the material accuracy of its basic financial statements and to report on internal controls related to those statements. As part of their annual audit, OSA performs financial aid audits that evaluate internal controls and tests compliance with federal aid programs. All reports are then submitted to the federal government as part of the State of North Carolina single audit [8].

A&T's financial aid programs are audited annually by OSA as required by the Office of Management and Budget (OMB) Circular A-133 and the Single Audit Act. However, the financial aid program at A&T is not selected every year as part of the Student Financial Assistance Cluster, which requires a more in-depth audit of compliance issues culminating in a separate Federal Compliance Audit Report for the University. For FY 2008, OSA included A&T in its Student Financial Assistance Cluster and issued a separate audit report. For FY 2007, A&T was included only in the Research and Development Cluster. Therefore, the financial aid audit for FY 2007 is included in the University's Financial Statement Audit Report. The engagement letters for the past two years [9] [10] define the parameters for the State Single Audit and the financial audit.

The Statewide Federal Compliance Audit Report for 2008 [11] noted one finding for financial aid, related to the over-awarding of aid to two students. The over-award occurred because the university made the award based on out-of-state residency tuition rates, but the students applied for and were determined eligible for in-state residency status. However, the awards were not reduced to reflect the lower, in-state tuition rates (pp. 8-9) [11]. The university concurred with the finding and has instituted a process for the Admissions Office to email the Financial Aid Office and the Treasurer's Office, notifying them of any changes in residency status. In addition, a weekly "residency status change" notification report is being developed. The Treasurer's Office will review all refunds in excess of $5,000 to ensure that there are no inconsistencies (p. 9) [11].

The State Financial Statement Audit Report for FY 2008 had no reportable findings for Financial Aid [12].

The State Financial Statement Audit Report for FY 2007, dated April 2008, [13] noted two weaknesses in internal controls related to the Financial Aid Office. The first was three questionable scholarship awards, totaling $5,300, out of 13 awards examined and totaling $18,466. These awards were made to relatives of university employees (pp. 43-44) [13]. There was no formal policy defining eligibility requirements, or the awarding process. The university concurred with the recommendations that the scholarships should be coordinated with the Financial Aid Office, that documentation should be maintained in the Financial Aid Office, and that criteria for the scholarship should be developed (p. 44) [13].

The second weakness [13] was the failure to return unearned student financial aid funds no later than 45 days after the date that it is determined that the student had withdrawn. The university computed unearned revenue of $18,512 for the fall 2006 semester related to unofficial withdrawals; however, the calculation was not done until January 2008. Unearned revenue for the spring 2007 semester was $87,771. Both amounts were paid back. The university concurred with the findings and responded that it would adhere to already established policies and procedures for all withdrawals (p. 52).

A&T has not received any limitations, suspensions, or terminations from the U.S. Department of Education with regard to student financial aid or other financial aid programs during the previous three years. There are no reimbursements or exceptional statuses in regard to federal or state financial aid. The University transacts monetary business with the Federal Government via electronic wire transfer, and has never been obligated to post a letter of credit on behalf of the U.S. Department of Education or other agencies.

A&T receives its student loan cohort default rate yearly. The rate remains below the 25% threshold for termination. The university's 2007 default rate was 11%. The default rate table covers fiscal year 2004 through 2007 [14].

Supporting Documents

[1] FISAP Validation and Application for AY 2008-2009

[2] Audit Sheet for Financial Aid

[3] Audit Sheet for Student No Discrepancies Financial Aid

[4] Audit Sheet for Student with Discrepancies Financial Aid

[5] U.S. Department of Education, Financial Aid Counselor Handbook

[6] U. S. Department of Education, Financial Aid Publications

[7] Financial Aid Banner Guide

[8] State Auditor Single Audit Website

[9] Audit Engagement Letter FY 2007

[10] Audit Engagement Letter FY 2008

[11] Statewide Federal Compliance Audit Report FY 2008

[12] State Financial Statement Audit Report FY 2008

[13] State Financial Statement Audit Report FY 2007

[14] Default Rates 2004-2007

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Last Updated ( Friday, 09 October 2009 08:59 )

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