Cisco College

Criteria: Per 34 CFR 685.301 (Federal Direct Loan Program), 34 CFR 690.83 (Federal Pell Grant Program), and the Federal Student Aid Handbook, institutions are required to report disbursement information to the COD system accurately and within the timeframes specified by the U.S. Department of Education. Timely and accurate reporting is necessary to ensure compliance with federal regulations and proper administration of Title IV funds. Condition: During our testing of the Student Financial Aid Cluster, we noted that the institution did not consistently submit student disbursement records to the COD system in a timely and accurate manner for both the Federal Direct Loan and Federal Pell Grant programs. Specifically, 6 out of 40 disbursement records tested were either submitted after the required deadline or contained errors that were not corrected promptly. Population and Sample Size: Number Dollars Questioned Cost Population 1320 $ N/A $ N/A Sample 40 N/A N/A Not in compliance 6 N/A N/A Effect: As a result, the institution is not in compliance with federal requirements for reporting to the COD system for both the Federal Direct Loan and Federal Pell Grant programs. This could result in delayed or improper disbursement of Title IV funds, potential loss of funding, or other administrative sanctions. Cause: The District updated the financial aid records in the internal student system but did not update the dates in COD in a timely manner. Recommendation: We recommend that the District strengthen reconciliation procedures to ensure that all loan changes entered in the internal system are promptly updated in COD and periodically verify that key data elements match.

Criteria: In accordance with CFR section 685.309(b)(2), "Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended."

Condition: We reviewed a sample of 40 students who received financial aid during the fiscal year. Of the 40 students tested, eight students withdrew and were not accurately reported to the NSLDS within the required 60-day period. Ten students graduated and were reported after the 60-day requirement. The other two students dropped to less than half-time and the status was not reported within the 60-day requirement.

Population and Sample Size:

Number Dollars Questioned Cost

Population 1,355 $ N/A $ N/A Sample 40 N/A N/A Not in compliance 20 N/A N/A

Effect: A student's enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies, all of which are negatively impacted by inaccurate and late reporting.

Cause: The District did not have a process in place to transmit reports to NSLDS during the time between the prior registrar’s retirement and the hiring of their replacement.

Recommendation: We recommend that at each NSLDS upload date, management review the NSLDS enrollment reporting upload to ensure student withdrawals during the period are appropriately reported in a timely manner.

Criteria: In accordance with CFR section 676.20(a)(1), "An institution may award an FSEOG for an academic year in an amount it determines a student needs to continue his or her studies. However, except as provided in paragraph (c) of this section, an FSEOG may not be awarded for a full academic year that is less than $100."

Condition: We reviewed a sample of 4 students who received FSEOG during the fiscal year. Of the 4 students tested, three students were awarded amounts less than the $100 minimum award.

Effect: The College fell out of compliance with the FSEOG regulations by disbursing amounts below the minimum award limit.

Cause: Management did not identify the correct limits outlined by the award.

Recommendation: We recommend that each award amount be reviewed as within the limits outlined in the compliance documents.

Criteria: In accordance with the Student Financial assistance cluster from the 2024 compliance supplement, "Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner."

Condition: We reviewed a sample of 40 students who received financial aid. Out of the 40 students tested, 23 students cost of attendance per the student records did not agree to the amounts reflected in COD originations records.

Effect: Incorrect or late reporting to the Common Origination and Disbursement (COD) System can lead to serious consequences for both institutions of higher education and their students. For institutions, delays in reporting may hinder access to federal funds, disrupt cash flow, and delay financial aid disbursements to students. Persistent errors can increase administrative burdens, require extensive corrections, and may lead to heightened scrutiny, such as being placed on Heightened Cash Monitoring (HCM) by the U.S. Department of Education (ED). Compliance failures can also damage an institution's reputation among prospective students and stakeholders. For students, these issues can result in delayed receipt of financial aid, insufficient or excessive funding, and complications with loan repayment, servicing, or eligibility for loan forgiveness. Timely and accurate reporting is critical to avoid these challenges and ensure smooth operations and compliance with federal regulations.

Cause: The District relied upon data exported from EDExpress to be accurately imported to COD. An error in the software caused inconsistent data to be pulled into the required fields, and the imports were not reviewed in detail.

Recommendation: We recommend that COD information is reviewed by an individual independent of the reporting process to verify that the amounts reported are accurate with the source data.