Abilene Christian University

Student Financial Assistance Cluster Federal Pell Grant Program, Assistance Listing Number 84.063 U.S. Department of Education Program Year 2024-2025

Criteria or specific requirement – Eligibility – Pell must be awarded to all students who qualify. (34 CFR 690 Subpart F)

Condition – A Pell-eligible student was under awarded Pell grants.

Questioned costs – $881 Calculated as the difference between what was awarded and what should have been awarded in accordance with the regulations.

Context – Out of the population of 4,164 students who received federal financial aid, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student was eligible for more Pell grants than they were awarded. The student added classes after the Pell grant was disbursed that made the student eligible for a higher Pell grant based on the student’s intensity.

Effect – A Pell eligible student was under awarded.

Cause – The University’s controls did not ensure changes in intensity were considered after Pell awards were made.

Identification as repeat finding, if applicable – N/A

Recommendation – The University should update their controls to ensure students with changes in intensity are properly awarded Pell grants.

Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the finding associated with Eligibility. The student’s Pell awards has already been corrected and accepted by COD. Management is working with IT to automate the enrollment change report to be sent on a weekly basis to validate that all increases in hours have been appropriately updated and processed.

Federal Pell Grant Program, Assistance Listing Number 84.063 Federal Direct Student Loans, Assistance Listing Number 84.268 U.S. Department of Education Program Year 2023-2024

Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information.

Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0

Context – Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change.

Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date

Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date

Other Records 14. Student changed his or her permanent address

The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student.

Effect – The University failed to report students' status changes, and did not report the status changes timely.

Cause – The University’s processes did not ensure status changes were reported timely and accurately.

Identification as repeat finding, if applicable – 2023-001 and 2022-001

Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner.

Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the findings associated with the lack of reporting enrollment changes. Due to the nature and timing of the findings, the University has begun the process of additional review within Banner ERP systems and reconciliation of the times being reported for mid-term changes. By doing so, the university plans to resolve any future misalignment of enrollment change dates between the Banner ERP system, Clearing House, and NSLDS.

Federal Pell Grant Program, Assistance Listing Number 84.063 Federal Direct Student Loans, Assistance Listing Number 84.268 Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007, Federal Work Study Program, Assistance Listing Number 84.033 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379 U.S. Department of Education Program Year 2023-2024

Criteria or specific requirement – Special Tests and Provisions – Incentive Compensation (34 CFR 668.14(b)(22)(i). An institution agrees in its Program Participation Agreement (PPA) that it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.

Condition – The University’s processes did not ensure that incentive payments were not made for covered activities under the ban on incentive compensation. Questioned costs – $2,000 Context – Out of the population of 339 employees in the University’s admissions/recruiting, financial aid, and registrar offices (or the equivalent of those offices), the University made supplemental payments to 4 employees related to covered activities under the ban on incentive compensation. The sample was not, and was not intended to be, statistically valid. Effect – the University was not in compliance with its PPA during the year.

Cause – There was a lack of communication or understanding of the requirements to all of the departments impacted.

Identification as repeat finding, if applicable – N/A

Recommendation – Controls and procedures should be reviewed to ensure compliance with the PPA.

Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings related to the Incentive Compensation. Processes have already been put in place to mitigate these findings in the future through a tenured bonus structure. Additional review will be required to ensure any enrollment raises and bonuses are based upon the tenured bonus structure now in place.

Federal Pell Grant Program, Assistance Listing Number 84.063 Federal Direct Student Loans, Assistance Listing Number 84.268 U.S. Department of Education Program Year 2022-2023

Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information.

Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0

Context – Out of the population of 1,079 students with student attendance changes required to be reported prior to July 19, 2022 or after February 28, 2023, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change.

Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date

Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date

Other Records 14. Student changed his or her permanent address

The University reported the incorrect Program Enrollment Effective Date for 10 students and did not timely report a status change for one student.

Effect – The University reported incorrect dates for students’ status changes and did not report the status changes timely.

Cause – The University’s processes did not ensure status changes were reported timely and accurately.

Identification as repeat finding, if applicable – 2022-001

Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner.

Views of responsible officials, reason for recurrence, and planned corrective actions – Management acknowledges and understands the findings associated with the reporting date of enrollment changes. Due to the nature and timing of the findings, the University has begun the process of additional review within the Banner ERP system and reconciliation of the times being reported for mid-term changes. By doing so, the university plans to resolve any future misalignment of enrollment change dates between the Banner ERP system, Clearing House, and NSLDS.

Federal Pell Grant Program, Assistance Listing Number 84.063 Federal Direct Student Loans, Assistance Listing Number 84.268 Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007 Federal Work Study Program, Assistance Listing Number 84.033 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing Number 84.379 U.S. Department of Education Program Year 2022-2023

Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.173(b); 34 CFR 668.22(e); 34 CFR 668.22(g) and 34 CFR 668.22(i). Federal Regulations state that the return of Title IV Funds must be made in the proper amount and in a timely manner as well as apply the return of Title IV Funds to Federal programs as required.

Condition – The University’s processes did not ensure the days in the semester were consistently calculated correctly to calculate the return of Title IV funds correctly.

Questioned costs – $1,106 (Assistance Listing Number 84.063 - $16; Assistance Listing Number 84.268 - $1,090)

Context – Out of the population of 266 students that withdrew during the year, 25 students were tested. During testing, nine instances were noted in which the total days in the semester were not calculated correctly which resulted in the calculation of an incorrect refund amount. The sample was not, and was not intended to be, statistically valid.

Effect – Title IV Funds were under returned to the U.S. Department of Education during the year.

Cause – Lack of oversight by management and of secondary review of calculations in a sufficient manner to resolve calculation errors.

Identification as repeat finding, if applicable – N/A

Recommendation – Controls and procedures should be reviewed to ensure calculation of Return of Title IV is completed accurately and properly reflects the student’s semester data.

Views of responsible officials and planned corrective actions – Management acknowledges and understands the findings of the Return of Title IV fund calculations related to the calendar setup. The calendar dates have been reviewed and corrected and all funds related to the recalculation have been returned to the Department of Education. Going forward, there will be an additional review of the calendar completed by the Director of Student Financial Services prior to the start of the academic year.