DALLAS CHRISTIAN COLLEGE

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: When students withdrew unofficially, the College did not always return unearned Title IV aid accurately and/or timely. Criteria: 34 CFR 668.22 Questioned Costs: $1,233 Context: Out of 9 students, 1 student who withdrew during the audit period tested had funds returned late due to misapplication of withdrawal regulations when a student does not begin attendance at least half time due to not beginning attendance in a class they were scheduled to attend. Another student had a correct calculation but the incorrect amount of a post-withdrawal disbursement of Pell resulting in $1,233 to return to the government. One unofficial withdrawal had the incorrect calendar used, and therefore, over returned $24 of federal direct loans. One student had all federal direct loan funds returned, resulting in an over return of $2,945 of loans. These students are in the process of being corrected. Cause: The College had some system notifications in place, but they were not sent timely and accurately to be shared with the third-party servicer, and the director of financial aid was not aware that not all information was being shared correctly. This resulted in misapplications of modular unofficial withdrawal students. Additionally, there was an incorrect calendar set up used for a type of student resulting in an inaccurate return. Effect: Incorrect amount of unearned Title IV funds was returned. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College work with the third-party servicer to ensure accurate and timely information is shared to effectively and efficiently process the returns of federal funds. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 - Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College had not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) during the fiscal year to comply with 16 CFR 314.4(c)(5). Subsequent to year-end, all but one system has MFA added. Cause: For the system that did not allow MFA natively in the prior year, a new system was identified, and the College moved to the new system shortly after fiscal year end. There is one additional system that the College is working to implement MFA as soon as possible. We commend the College for the substantial work done during the year. Effect: The College may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the College implement MFA on the one remaining system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Need Analysis and Estimated Financial Assistance DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: Errors in need analysis for federal financial aid led to inaccurate awarding and disbursing need based federal financial aid due to certain estimated financial assistance being set up as non-need based aid. Criteria: 34 CFR 685.203 Questioned Costs: $3,512 Context: Two students out of 51 were over awarded subsidized loans. Cause: Some institutional scholarships are set up as non-need based aid but not flagged as estimated financial assistance, so systematically it looked like there was need when need had been met. Effect: Students not awarded need based federal aid according to eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure that all scholarships are flagged as estimated financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) correctly for one student. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 51 students tested, 1 student who withdrew after the fall semester was not reported as withdrawn. This was corrected during the audit process. Cause: This was an oversight. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Yes, 2022-002. Recommendation: We recommend the College put a system in place to ensure that students who leave after one semester are reported as withdrawn and that the College is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The FDL amounts posted to student account did not always agree to disbursement records reported to Common Origination and Disbursement (COD) for one student. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: One of 51 students tested, 1 student had a COD loan disbursement amount error of approximately $1,000 that was not caught in the monthly reconciliation. Cause: There was a miscommunication between the third party administrator and the College, and the monthly reconciliation process did not identify the discrepancy. Effect: Inaccurate FDL reporting can impact a student’s interest accumulating period based on the dates and amounts of the loan disbursement dates as well as the monitoring of FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Yes, see 2022-003. Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts and that all dates and amounts be part of the monthly reconciliation process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.