Ope Id No: School Name: Subfolder: Doc Type: Rec Date: Org Date: School Year: ACN: PRCN: Box ID: Unique ID: Index Sheet 03903500 SOUTHERN TECHNICAL INSTITUTE Pro gram Review/FPRD FPRD with Attachments 11/09/2012 2012 201140427638 1407 SC1000000793416 November 8, 2012 Mr. John Euliano, President Southern Technical College 1485 Florida Mall Avenue Orlando, FL 32809-0000 UPS Tracking #12 A54 67Y 01 9205 1089 RE: Final Program Review Determination OPE ID: #03 903500 PRCN: #201 140427638 Dear Mr. Euliano: The US. Department of Education?s (Department?s) School Participation Division - Atlanta issued a program review report on March 15, 2012 covering Southern Technical College?s administration of programs authorized by Title IV of the Higher Education Act of 1965, as amended, 20 U.S.C. 1070 et seq. (Title IV, HEA programs), for the 200972010 and 201012011 award years. ?nal response was received on June 13, 2012. A copy of the program review report (and related attachments) and STC?sresponse are attached. Any supporting documentation submitted with the response is being retained by the Department and is available for inspection by STC upon request. Additionally, this Final Program Review Determination (F PRD), related attachments, and any supporting documentation may be subject to release under the Freedom of Information Act (F 01A) and can be provided to other oversight entities after this FPRD is issued. Purpose: Final determinations have been made concerning all of the outstanding ?ndings of the program review report. The purpose of this letter is to: (1) identify liabilities resulting from the ?ndings of this program review report, (2) provide instructions for payment of liabilities to the Department and (3) notify the institution of its right to appeal. The total liabilities due from the institution ?'om this program review are $228,785.00. - This FPRD contains detailed information about the liability determination for all ?ndings. Federal Student Aid, School ParticipationDivision - Atlanta 61 Street, Room 18T40, Atlanta, GA 30303-3104 FederalStudent Ad mom-r In 03"? of u. Sonthern Technical College OPE 03903500 PRCN NumbersE 20I140427638 Page 2 of 3' Appeal Procedures: This constitutes the Department?s FPRD with respect to the liabilities identi?ed from the March 15, 2012 program review report. If STC wishes to appeal to the Secretary for a review of monetary liabilities establishedby the FPRD, the institution must ?le a written request for an administrative hearing. The Department must receive the request no later than 45 days from the date STC receives this FPRD. An original and four copies of the information submits must be attached to the request. The request for an appeal must be sent to: Ms. Mary E. Gust, Director Administrative Actions and Appeals Service Group US. Department of Education Federal Student AidfPC 830 First Street, NE - UCP3, Room 84F2 Washington, DC 20002-8019 appeal request must; (1) indicate the ?ndings, issues and facts being disputed; (2) state the institution?s position, together with pertinent facts and reasons supporting its position; i I (3) include all documentation it believes the Department should consider in support of the appeal. An institution may provide detailed liability information from a complete ?le review to appeal a projected liability amount. Any documents relative to the appeal that include PII data must be redacted except the student?s name and last four digits of hisi'r her social security number (please see the attached document, ?Protection of Personally Identi?able Information,?- for instructions on how to mail ?hard copy? records containg and . (4) include a copy of the FPRD. The program review control number (PRCN) must also accompany the request for review. If the appeal request is complete and timely, the Department will schedule an administrative hearing in accordance with 487(b)(2) of the HEA, 20 U.S.C. 1094(b)(2). The procedures followed with respect to appeal will be those provided in 34 CPR. Part 668, Subpart H. Interest on the appealed liabilities shall continue to accrue at the applicable value of funds rate, as established by the United States Department of Treasury, or if the liabilities are for refunds; at the interest rate set forth in the loan promissory note(s). Record Retention: Program records relating to the period covered by the program review must be retained until the later of: resolution of the loans, claims or expenditures questioned in the program review; or the end of the retention period otherwise applicable to the record under 34 CPR. (6X2): and Southern Technical College OPE 03903500 PRCN Numberst 201140427638 Page 3 of 3 The Department expresses its appreciation for the courtesy and c00peration extended during the review. If the institution has any questions regarding this letter, please contact Pat Gilbert at (404) 974-9292. Questions relating to an).r appeal of the FPRD should be directed to the address noted in the Appeal Procedures section of this letter. ibxs) Lharles 9 Director Enclosure: Protection of Personally Identi?able Information cc: Mr. Richard Bennett, Financial Aid Administrator FL Commission for Independent Education - Florida Department of Education Accrediting Council for Independent Colleges and Schools PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION Personally identi?able Information (Pll) being submitted to the Department must be protected. PM is any information about an individual which can be used to distinguish or trace an individual's identity (some examples are name, social security number, date and place of birth). being submitted electronically or on media ?oppy disk, DVD) :must be The data must be submitted in a .zip ?le with 'Advanced Standard (AES) (256-bit is preferred). The Department uses WinZip. However. ?les created with other software are also acceptable, provided that they are compatible with WinZip (Version 9.0) and - are with AES Zipped ?les using WinZip must be saved as Legacy compression (Zip 2.0 compatible). The Department must receive an access password to view the information. The password must be e-mailed separately from the data. The password must be 12 characters in length and use three of the following: upper case letter, lower case letter, number, special character. A manifest must be included with the e?mail'that lists the types of ?les being sent (a copy of the manifest must be retained by the sender). Hard copy ?les and media containing must be: - sent via a shipping method that can be tracked with signature required upon delivery i - double packaged in packaging'that is approved by the shipping agent (FedEx, DHL, UPS, USPS) -. labeled with both the 'To" and "From" addresses on both the inner and outer packages - identi?ed by a manifest included in the inner package that lists the types of ?les in the shipment (a copy of the manifest must be retained by the sender). Pli data cannot be Sent via fax. FederalStudentAid An OFFICE a! the U.S. DEPARTMENT of EDUCATION Prepared for Southern Technical- College OPE 03903500 201 140427638 Prepared by: U.S. Department of Education Federal Student Aid School Participation Team - Atlanta Final Program Review Determination November 8, 2012 I 61 Street, S.W., Room 18T40, Atlanta, GA 30303-3104 FederalStudentAid- I An OFFICE of the U.S. DEPARTMENT of EDUCATION Prepared 'for Southern Technical College OPE 03903500 20114042?638 Prepared by: - - U.S. Departmenth Educatiml Federal Student Aid School Participation Team - Atlanta Final Program Review Determination November 8, 2012 6] Street, S.W., Room 18T40, Atlanta, GA 30303-3104 *?Southern Technical College OPE 03903500 . 201140427638 Page 2 Table of Contents - Page Institutional Infonnation .. Scope of Review .. Findings and Final Determination .. Resolved Findings Resolved Finding with Comments Findings with Final Determinations Finding Con?icting Information Finding Incomplete Verification Finding Pell Underpayment/Overpayments Summary of Liabilities Payment Instructions Appendices Appendix A Student Sample Appendix Finding #1 (2009/2010) Projection Matrix Appendix Finding #1 (2010/2011) Projection Matrix Appendix Finding #1 Cost of Funds Appendix Finding #2 Cost of Funds Appendix Estimated Actual Loss Formula Appendix Finding #2 Estimated Actual Loss worksheet Appendix Finding #5'2009/2010 File Review Appendix i Finding #5 2010001 1' File Review Appendix Finding #5 Cost of Funds . Appendix Finding #5 2009/2010 Less Than In Time Appendix -?"Finding #5 2010/2011 Less Than Time Appendix Finding #5 Estimated Actual Loss Worksheet Appendix School?s Response Appendix 0 Program Review Report Appendix FEDWIRE Form one 41w Win53 "Southern Technical College . OPE 03903500 20114042763 3 Page 3 A. Institutional Information Southern Technical College 1485 Florida Mall Avenue Orlando, FL 32809-0000 Type: Proprietary Highest Level of Offering: Associate?s Degree Accrediting Agency: Accrediting Council for Independent Colleges and Schools - Current Student Enrollment: 1134 (2010/2011) of Students Receiving Title IV: 99.33% (2010/2011) Title IV Participation: Grants Administrative and Payment System (G5): - 2009/2010 Federal Peli Grant $5,334,003 Federal Supplemental Educational Opportunity Grant (FSEOG) 19,779 Academic Competitiveness Grant (ACG) 11,868 Federal DireCt Loan (DL) . $7,131,330 Default Rate FFELIDL: 2009 13.3% - 2008 - 3.2% 2007r - 9.6% 201012011 315 7,130,094 25,000 10,015 $12,264,937 ?Southern Technical College OPE 03903500 201140427638 Page 4 B. Scope of Review The US. Department of Education (the Department) conducted a program review at Southern Technical College (STC) from August 29, 2011 to September 2, 2011. The review was conducted by Pat Gilbert, Sherry Blackman and Angelique James. The focus of the review was to determine compliance with the statutes and regulations as they pertain to the institution's administration of the Title IV, HEA programs. The review consisted of, but was not limited to, an examination of policies and procedures regarding institutional and student eligibility, individual student ?nancial aid and academic ?les, attendance records, student account ledgers, and ?scal records. A sample of 30 ?les was identi?ed for review from the 2009/2010 and 2010/2011 (year to date) award years. The ?les were selected randomly from a statistical sample of the total population receiving Title IV, HEA program funds for each award year. Appendix A lists the names and partial social security numbers of the students whose ?les were examined during the program review. A program review report was issued on March 15, 2012. Disclaimer: Although the review was thorough, it cannot be assumed to be all-inclusive. The absence of statements in the-report concerning speci?c practices and procedures must not be construed as acceptance, approval, or endorsement of those speci?c practices and procedures. Furthermore, it does not relieve STC of its obligation to comply with all of the statutory or regulatory provisions governing the Title IV, HEA programs. Resolved Findings STC has taken the corrective actions necessary to resolve findings 3?4, 6-8, and 10?13 of the program review report. Therefore, these ?ndings may be considered closed. Appendix contains theinstitution?s written response related to the resolved ?ndings. Findings requiring further action by STC are discussed below. ?Southern Technical College OPE iDii 03903500 201140427638 . Page 5 Resolved Finding with Comments The following program review ?nding has been resolved by the institution, and may be considered closed. This ?nding is included solely for the purpose of discussing resolution of the ?nding. Finding Invalid High School Diploma Citation Summary: 34 C.F.R. states a student is eligible to receive Title IV, HEA program assistance if the student has a high school diploma or its recognized equivalent. Noncompliance Summary: We students appear to have invalid High School Diplomas. - Student #22 ?s attestation stated he received a GED from Continental Academy located in Orlando, Florida in 2006. Student #25 ?s attestation stated he received a High School Diploma from-Colonial High School in Orlando, Florida in May 2003. Required Action Summary: The institution had to implement procedures to ensure the validity of high school diplomas before students are admitted and disbursed Title IV funds. A copy of the procedures had to be submitted in response to this report. Response: The institution developed a list of ?Unacceptable High Schools? whose graduates do not qualify for admission to the College. Any student who clajm5 . graduation from'a high school on the list must be refused admission to the College by the admissions representative. In addition, the Associate Dean is required to review all admission documentation. If a student is erroneously accepted far admission without a proper attestation, the Associate Dean is required to reverse the student?s acceptance as a student at the College. - Final Determination: If a school has reason to believe that a high school diploma is not valid or was not obtained from an entity that provides secondary school education, the institution must evaluate the validity of the student?s high school completion. Students who indicate on their FAFSA that they graduated high school must give the name, city, and state of the high school. FAFSA on the Web will not allow students to skip these items, and it will have a drOp-down list of both public and private high schools populated by the National Center for Education Statistics (NCES). Inclusion on the list does not mean that a Southern Technical College OPE 03903500 201140427638 Page 6 diploma from the school is valid, nor does exclusion from the list mean that the diploma is invalid. Acceptable documentation for checking the validity of a student?s high school completion can include the diploma and a ?nal transcript that shows all the courses the student took. For students who completed their secondary schooling outside the United States, comparable documents can help, as can the services of companies that determine the validity of foreign secondary school credentials. Another resource is the state department of education in which the high school is located, if that department has jurisdiction over the high-school. Colleges are also free to consult with each other as they develop their procedures for checking the validity of high school diplomas. The Department does not expect schools to check the high school data for every student against other information obtained by the school during admissions, but if a school has reason to believe the high school diploma is dubious?cg, the college knows the student bought the diploma or transcript and was required to perform little orno work?the diploma must be validated. A student?s self-certi?cation is not suf?cient to validate the high school diploma that is in question. It should be remembered that for a college to be an eligible institution, it must admit as regular students only those with a high school diploma or the recognized equivalent or who are beyond the age of compulsory school attendance. practice of simply maintaining a list of unacceptable high schools and reviewing that list for admission is not suf?cient. The institution should develop procedures to aid in the identification of invalid high school diplomas when an unfamiliar diploma or credential is presented to the College. Findings with Final Determinations The program review report ?ndings requiring further action are summarized below. At the conclusion of each ?nding is a summary of response to the ?nding, and the Department?s ?nal determination for that ?nding. A copy of the program review report issued on March 15, 2012 is attached as Appendix (0). Finding Con?icting Information Citation Summary: The ability of an'institution to coordinate the information it collects and to resolve discrepancies are critical elements in an evaluation of its administrative capability. Regulations require institutions to develop an adequate system to identity and resolve discrepancies in the information that the institution receives from different sources with respect to a student ?s application for ?nancial aid under Title I V, HEA programs. 34' GER. and (19 Technical College OPE 03903500 201140427638 Page 7 - Noncompliance Summary: STC failed to resolve the discrepant information'for the below students: Student #5 The FAFSA signed on llr?6f2009 shows the student as single. Leave of Absence (LOA) papenvork dated 4/5/2010 and ll/22/201 0 shows the student reason for the LOA as ?separation with spouse. . Student #16: The student was not selected for veri?cation; however the student had a code that needed to be resolved and the institution should have resolved all the discrepant infarmation. The enrollment application shows the student as married. The student reported single on the FAFSA and reported only his income. The Household size was reported as 3. Student #22: The student was not selected for veri?cation. However, the student has a code that needed to be resolved and the institution should have resolved all the discrepant information. i - Enrollment Agreement and Verification Worksheet show ?married? and the FAFSA reported ?single?. - . Incorrect status of ?Head of Household used on Tax Form 1040 - code for Selective Service was not resolved Student #25: The student was not selected for verification for the 2010/2011 award year but was selected for the 2009/2010 award year. The enrollment agreement shows the student as a single male and the student answered ?no to the question on enrollment agreement regarding are you a single parent. The student FAFSA reported 2 in house- hold size and on the verification worksheet for 2009/20l 0. The student also ?led an amended tax return for 2008 changing the ?ling status as ?single? rather than "head of househol - Student #28? The student was not selected for verification. However, the enrollment - agreement shows the-student as a single male and not a single parent. The shows 2 in household size and the student answered ?yes to the question regarding children you support. Required Action Sammaqi: In response to this ?nding, STC was required to resolve the discrepant in?irmation for the students listed above and provide supporting documentation. TC was also required to conduct a ?le review of all the students for the 2009/2010 and 201r 0f201 award years to determine if corrections to the household size would result in-a change to the Estimated Family Contribution (EF C) where there is con?icting information regarding household size and answers given by students on either the FAFSA or the institution?s enrollment agreement. In lieu ofper?irming a file review for the entire population (155 l) for 2009/2010 and (l 932) for the 20l 0/201 award year to determineactual liabilities, STC had the option i Southern Technical College OPE 03903500 201140427638 Page 3 of performing this file review for only the remainder of the statistical sample not tested by --the Department during the program review (3 08 for 2009/2010 and 320 for 2010/2011) in the statistical samples. ST was required to engage an Independent Public Accountant (IPA) to test the ?le review completed The was required to develop a set of procedures designed for testing the accuracy and completeness of the ?le review. The suggested procedures were required to be provided to Pat Gilbert within 30 days of the institution ?5 receipt of this Program Review Repart. Response: STC completed its review of the remaining students in the statistical samples for the 2009/2010 (308) and 2010/2011 (320) award years. The required electronic spreadsheet and IPA attestation were included with response. Regarding the students speci?cally referred to in the ?nding, the information provided by STC resolved student #3 16, 22, and 25. The institution agreed with the ?nding for student #28. As for Student STC claimed that the information provided by the student was consistent and indicated that the student was single. STC further alleged that the leave of absence (LOA) references in the student?s academic ?le (as distinct from the ?nancial aid ?le) were completed and placed in the ?le by the Registrar and re?ected only the Registrar?s perception of the situation. The Department rejects this conclusion. The discrepant information regarding the marital status was not resolved. comments regarding the Registrar?s perception does notconstitute resolution. The student was disbursed Pell funds for 2009/2010 in the amount of $3,567. This amount will be'added to the liabilities in the projection matrix. The institution ?thher stated that results from the report showedthat there was a very small percentage of ?les with discrepant information. Out of the population of ?les examined, there was an error rate of 0.34% of the ?les in the 2009/2010 award year and 1.61% of the ?les in the 2010/2011 award year. Based on the resolution of the ?les identi?ed above and the report of the audited ?lereview, the institution believes that thereis no material pattern of failing to resolve con?icting information. Final Determination: The Institution failed to properly resolve the discrepant information for the two students identi?ed above-- #5 5 and 28 and the funds must be returned. The Department has projected liabilities based on the results of the review of statistical samples completed by STC. An average liability was'ealculated for the statistical samples for each Title IV, HEA program with liabilities and this average was multiplied against the population being reviewed. Southern Technical College OPE [Dali 03903500 201140427638 Page 9 response indicated that the total amount of Pell Grant liabilities in the statistical sample for the 2009l2010 award year is $7,134 plus the $3,567 for student #5 equals $10,701. An average liability of $34.74 was calculated by dividing $10,701 by the number of students in the statistical sample (308). This average liability was then multiplied by the total number of students in the population (1551) from which the statistical sample was derived. See Appendix response indicated that the total amount of Pell Grant liabilities in the statistical sample for the 2010t2011 award year is $5,750 plus the $1,850 for student #28 equals $7,600. An average liability of $23.75 was calculated by dividing $7,600 by the number of students in the statistical sample (3 20). This average liability was then multiplied by the total number of students in the pepulation (193 2) from which the statistical sample was derived. See Appendix Therefore the Pell Grant projected liability amount for this ?nding that STC must pay to the Department is $53,881.74 for 2009/2010 and $45,885.00 for 20102011 for a total of $99,766.74. Theinstitution is also liable for the cost of those funds (Appendix D) in the amount of $1,246.75 Total Liabilities for this ?nding: $101,013.49 Finding Incomplete Verification Citation Summon}: if the Central Processing System (CPS) selects an application for. veri?cation, an institution must vert'?z?ve major data elements (household size, number enrolled in college, aajfusted gross income (AGI), US. income tax paid, and certain untaxed income and bene?ts). An institution can verijjz and US. income tax paid by getting a copy of the'signed US. income tax return. 17a copy of the tax return is not available, the student must instead submit a copy of any lRSform that lists tax information and provides the in?nrmation needed for veri?cation. The form be signed by the student unless the IRS sent the form directly to the school. 34 C.F.R. 668.56, 668.57 . Noncompliance Summary: Student #10 was selected for verification for the 2008/2009 award year. The FAFSA shows the student as married. The student ?s?ling status on the 2008 tax return shows ?head of household; this is an incorrect ?ling status. The student was disbursed Pell funds in the amount of$3 1'54, subsidized loans of $3 5 00 and unsubsidized loans of $585 0. or the 2009/2010 award year, the student was not selected for veri?cation. However, the tax return only shows 3 exemptions but the household size is 6 on the FAFSA. The student was disbursed Pell funds in the amount of $535 0, subsidized loans of 3 45 00 and unsubsidized loans of 6000. Required Action Summary: ST had to obtain the proper IRS tax forms to complete the verification process. ?Southem Technical College OPE 03903500 201 140427638 Page 10 STC Response: STC concurred with the ?nding and was unable to provide the required corrected tax documents. Final Determination: The Institution failed to complete veri?cation and must return for the 2008/2009 award year $3,154 in Pell funds, $3,500 in Subsidized DL funds and $5,850 in Unsubsidized DL funds. For the 2009l2010 award year, STC must return $5,350 in Poll funds, $4,500 in Subsidized DL funds and $6,000 in Unsubsidized DL funds. - Pell ?mds identi?edtotal $8,504. The institution is also liable for the cost of those funds (Appendix E) in the amount of $341.21 Direct Loan funds identi?ed total $19,850; however the Department will use the Estimated Actual Loss (EAL) formula (Appendix F) to establish liabilities. In lieu of requiring the institution to assmne the risk of default by purchasing the ineligible loan from the holder, the Department has asserted .a liability not for the loan amount, but rather for the estimated actual or potential loss that the government may incur with respect to the ineligible loan or loan amount. to the Department that has resulted or will result from those ineligible loans is based on most recent cohort default rate available during the disbursement period. As a result, the estimated actual loss that STC must pay to the Department for the Incomplete Veri?cation is $2,535.72. A copy of the results of that caICulation is included as Appendix G. Total Liabilities for this ?nding: $11,380.93 - Finding Pell Underpaymentleverpayments Citation Summary: 13f an institution uses credit hours and academic terms to measure a student is progress, then the student 's enrollment status full-time, three-quarter time, half-time or less than half-time) is used to calculate the amount of the student ?s Federal Pell Grant payment. A school may use its own standards for enrollment status, provided the standards meet the minimum requirements de?ned in regulations. 34 C.F.R. 690. 63 Noncompliance Summary: The students identified below were overpaid due to their enrollment status: Student Enrolled for 6 hours (1/2 time) for Summer C. The student was disbursed Pell funds in the amount of 31 2'84 for full time status. The student should have received $891.00. The school returned $189.52 on ll/lr?2009 based on the student ?s withdrawal. - Southern Technical College OPE 03903500 201140427638 Page 11 Student Enrolled?ir 1.5 hours for Winter a The student was disbursed $1850 in Pell funds for full-time enrollment. The student should have only received 3 1 3 88. Student #12: Enrolled for 9 hours for Summer C. The student was disbursed $1850 in "Pell funds for full-time enrollment. The student should have only received $1388. The student was enrolled for Winter and Winter for 9 hours-and received Pell funds in the amount of$ 1850. The student should have only received $1388. Student #13: Enrolled for 10.5 hours for Summer C. The Pell funds were not disbursed prior to the student withdrawing; however the school used the full time Pell of$1 783 in the R2T4 calculation. Student #16: Enrolled for 4.5 hours ?ess than ?72 time) for Summer B. The student was disbursed $1850 in Pell funds for full-time enrollment. The student shouldhave only received $463. . Student #18: Enrolled for 10.5 hours (314 time) for Winter and was paid $1850 in Pell funds for fullrtime enrollment. The student should have only received $1388. Student #28: Enrolled for Spring term for 18 hours from 6/13/2011 9/1/2011. The student signed an appeal form showing he was recalled to attend Army trainingin Cha??ee, Arkansas ?'om 7/15/2111 1 7130/2011. The attendance record shows the student was required to attend 64 hours and only attended 12 hours during that time period The form was not processed due to excessive absences. Required Action Summon): STC was required to conduct a?le review of all students for the 2009/2010 and 2010/2011 award years and identity additional students who received ineligible Title 1 funds. STC had to engage an 1ndependent Public Accountant (IPA) to test the ?le review completed by STC. STC also had to develop and submit with its. response, procedures which will ensure that, in the future, Title IV funds are calculated using the correct enrollment status. STC Response: Regarding the students speci?cally referred to in the ?nding, the information'provided by STC resolved student #3 12, 13, 16, 18, and 28. The institution agreed with the?nding for student #5 3 and 7. The IPA found a 0.28% overpayment error rate for the 200912010 award year and an underpayment error rate of 0.13% for the 201012011 award year, resulting in an - overpayment of Pell funds for 200912010 of $14,104 and an underpayment of $8,901 for the 2010/2011 award year. Southern Technical College I - 7 - . - OPE 03903500 - 201140427638 Page 12 . Final Determination: Student #7 will be added to the ?le review spreadsheet for the 2009/2010 award year in the amount of $462.50. Student #3 was already included on the spreadsheet. - STC conducted a 100% ?le review for the 2009/2010 and 2010/2011 award year. The results of the review identi?ed Peli Grant overpayments for the 2009/2010 award year for 87 students (86 identi?ed through ?le review plus student in the amount of - $49,612.53. The Pell Grant overpayments for the 2010/2011 award year were $31,976.87 for 52 students. See Appendices and I. Please note that because Federal Pell Grants are student speci?c underpayments cannot be netted with overpayments. . The Institution is also liable for the cost of those funds (Appendix J) in the amount of $1,075.07. I As a result of the ?le' review conducted, several students were identi?ed as being enrolled less than 1/2 time. For the 2009/2010 award year, 11 students were identi?ed for a total of $22,384.00 in Subsidized DL funds and $38,825.00 in Unsubsidized DL funds. For the 2010/2011 award year, 26 students were identi?ed for a total of $56,248.00 in Subsidized DL funds and $70,298.00 in Unsubsidized DL funds. See Appendices and Direct Loan funds identi?ed total $187,755.00; however the Department will once again use its EAL formula for establishing liabilities. As a result the estimated actual loss that STC must pay to the Department for the ineligible loans is $33,724.68. A copy of the results of that calculation is included as Appendix M. Southern Technical College OPE 03903500 201140427638 Page 13 D. Summary of Liabilities Established Liabilities Initial Liabilities Pell (Closed FELIEAL Award Year Fin . 99,767 Fin #2 8,504 5 81,590 Subtotal 1 $189,861, InterestISA #1 $1 47 htteresb?SA #2 341 $2,536 1616356511115 $1,075 $33,725 5111516131 2 $2,663 $36,261 TOTAL $192,524 $3 6,261 Payable To: . Totals $228,785 Department $192,524 $36,261 $228,785 Students $0 I $0 $0 .1 Total Liabilities $192,524 $36,261 . $228,785 E. Payment Instructions STC owes to the Department $228,785.00. Payment must be made by forwarding a check made payable to the Department of Education? to the following address within 45 days of the date of this letter: US. Department of Education PO. Box 979026 . St. Louis, MO 63197-9000 - Southern Technical College OPE 03903500 20114042?633 Page 14 Remit checks only. Do not send correspondence to this address. Payment must be made via cheek and sent to the above Post Of?ce Box, payment andfor adjustments made via GAPSIGS will not be accepted as payment of this liability. The following identi?cation data must be provided with the payment: Amount: $228,785 DUNS: I 106015451 TIN: 593 729236 PRCN: 201 14042763 8 STC owes to the Department $228,785.00. .This liability must be paid using an electronic transfer of funds through the Treasury Financial Communications System, which is known as FEDWIRE. STC must make this transfer within 45 days of the date of this letter. This repayment through FEDWIRE is made via the Federal Reserve Bank in New York. If bank does not maintain an account at the Federal Reserve Bank, it must use the services of a correSpondent bank when making the payments through FEDWIRE. Any liability of $100,000 or more identi?ed through a program review must be repaid to the Department via FEDWIRE. The Department is unable to accept any other method of payment in satisfaction of these liabilities.? Instructions for completing the electronic fund transfer message format are included on the attached EDWIRE form. (Appendix P). The disbursement record for each student must be adjusted in the Common Origination and Disbursement (COD) System based on the recalculated amount identi?ed in the attached Appendices and I only. - If the adjustment to the disbursement record(s) creates a negative balance, the difference must be returned to GS electronically. A copy of the adjustment to each student?s COD record, as well as proof of the return of funds, if applicable, must be sent to Pat Gilbert within 45 days of the date of this letter. - Terms of Payment As a result of this ?nal determination, the Department has created a receivable for this liability and payment must be received by the Depaitment within 45 days of the date of this letter. If payment is not received within the 45-day period, interest will accrue in increments from the date of this determination, on the amountsowed to the Department, at the current value of funds rate in effect as established by the Treasury Department, until the date of receipt of the payment. STC is also responsible for 'Southern Technical College OPE 03903500 201140427638 Page 15 repaying any interest that accrues. If you have any questions regarding interest accruals or payment credits, contact the Department?s Accounts Receivable Group at (202) 245-3080 and ask to speak to account representative. If full payment cannot be made within 45 days of the date of this letter, contact the Department?s Accounts Receivable Group to apply for a payment plan. Interest charges and other conditions apply. Written request may be sent to: US. Department of Education OCFO Financial Management Operations Accounts Receivable Group 550 12th Street, S.W., Room 6111 Washington, DC 20202-4461 Attn: Cindy Dixon If within 45 days of the date of this letter, STC has neither made payment in accordance with these instructions nor entered into an arrangement to repay the liability under terms satisfactory to the Department, the Department intends to collect the amount due and payable by administrative offset-against payments due STC from the Federal Government. STC may object to the collection by offset only by challenging the existence or amount of the debt. To challenge the debt, STC must timely appeal this determination under the procedures described in the "Appeal Procedures" section of the cover letter. The Department will use those procedures to consider any objection to offset. No separate appeal opportunity will be provided. If a timely appeal is ?led, the Department will defer offset until completion of the appeal, unless the Department determines that offset is necessary as provided at 34 C.F.R. 30.28. This debt may also be referred to the Department of the Treasury for further action as authorized by the Debt Collection Improvement Act of 1996. - - Accounting?Document -'Prior Year Monetary Recovery Institution: Southern Technical College City, State: Orlando. FL 32609?0000 PRCN: 140427638 TIN: 593729236 DUNS: 106015451 Reviewer: Pat Gilbert Regign: IV Date: October 31, 2012 Programs Type Amount Funding Code Object Class Federal Peil Grant Principal $81,466.00 3220RNOYR 69017 - (Closed AY) Interest 8 2,663.00 1435RNOYR 64020 FSEOG Principal 3220RNOYR 69017 interest 1435RNOYR 64020 FWS Principal 3220RNOYR 69017 Interest 1435RNOYR 64020 ACG Principal 3220RNOYR 69017 Interest 1435RNOYR 64020 National SMART Principal 3220RNOYR 69017 Interest 1435RNOYR 64020 TOTAL {Pall-Closed Principal 3220RNOYR 69017 AY, FSEOG, FWS, Interest 1435RNOYR 64020 ACG, National SMART) Direct Loan and Principal 4253XNOYR 53020 or 53010 Direct Loan EAL Interest $36,261.00 4253XNOYR 53040 FFEL and Interest! I 425111110112 53020 FFEL SNEAL I Federal Perkins Principal 29151211011? 53054 Adii rows if Amount GS Program necessary Award Negative Cash Program . - Balance (Fell. FWS. Pell (08I09) Principal 3,154.00 3876FNOYR 69020 FSEOGZ ACG. SMART. Pell (09110) Principal $65,663.53 3875FNOYR 69020 Pell (10/11) Principal $39,570.37 3875FNOYR 69020 Program Interest 1435RNOYR. 64020 Sent to Treasury Leave Principal 3875FNOYR 69020 DL Unsuhstantlatedl' blank . EXCESS Cash Leave interest 4253XNOYR 53040 Sent to BL blank Fund Comments: Example of 65 Allan 11 (P663P104306, first digits code unique to school) 5 digits program, next 2 digits award year, next '4 Page 1' of 1 Version: April 4, 2011 See FPRD Distribution Form for distribution information for this form and related p?gram review documents. Checklist - FPRD Review Page 1' of 1 Version: January 7, 2011 Southern Technical College OPE 03903500 201140427638 Appendix A Student Sample Student Sample 200912010 Student?s Name Student?s SSN (last four 7 clim' Only) 20] Appendix A - Southern Technical College OPE 03903500 201140427638 Appendix Findng #1 20093010 Projection Matrix Statistical Sample Projection Matrix - Single Finding Institution: Southern Technical College Population Size Statistical Sample Size Year Name: 1551 308 SSN: Finding: #1 Con?icting Information Pell 0.00 0.00 0.00 3557.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 . 0.00 0.00 0.00 0.00 0.00 0.00 0-00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 . 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0:00 000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 7134.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0. 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0. 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 Liability Projection Total Liability in Sample Number of Students in Population Number of Students in Sample Average Liability Per Student in Sample UCL: 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Pelt $10,701.00 f. 23? . "r 3:21 551 a? M1 ?35 A 331243264183 Projected Liability WEE LCL: UCL: 1316501335) 051% Projected Fatal Error Rate 0.6% LCL: Standard Deviation PluslMinus for UCULCL Records. 4. -. . . 0.6% ?4535385343 .r a ,3 - i Southern Technical College OPE 03903500 201140427638 Appendix Finding #1 20101201 1 Projection Matrix i Statistical Sample Projection Matrix - Single Finding Institution: Southern Technical College Pophlation Size . StatisticalSample Size Year Name: 1932 320 SSN: Finding: #1 Conflicting Information Pell 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1850.00 07.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 .000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 000 0.00 0.00 Appendix 99999999999 999999999. (1.00 0.00 0'00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5750.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0. 00 0. 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 . 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0. 00 0.00 0.00 0.00 0.00 0.00 000 0:00 0.00 0.00 0.00 Liability Projection Total Liability in Sampie - Number of Students in Population Number of Students in Sample Average Liability Per Student in Sample UCL: 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 . 0 Fall $7 ,600.00 "52:31:11 932.? 713- 13?3207: :11;1 5:11 5170* Projected Liability if LCL: UCL: Projected Fatal Error Rate Standard Deviation LCL: Plus?u'linus for UCULCL Records 3312353242 Southern Technical College OPE 03903500 201140427638 Appendix Finding #1 Cost of Funds ineligible Disbursements (Non-Loan) - Cost of Funds and Administrative Cost Allowance Name Of Institution: Southern Technical College - Finding #1 A . - iiDaf?. Days" 20092010 3 881.74 Pell Grant 613012010 3? 512012 6241 201012011 5 885.00 Pell Grant 6/30/2011 3(15/2012 259 1.00% 53 881.?4? 921.16 1.00% 45 885.00 325.59 I I flPPeJ?oli?b Antoni-Its . Southern Tachnical College OPE 03903500 201140427638 Appendix Finding #2 Cost of Funds Ineligible Disbursements (Non-Loan) - Cost of Funds and Administrative Cost Allowance Name of institution: Southern Technical College - Finding}?! . l. - - I _r_rlnelig?ibie' - I Disbursenje?Retur?faid of. I '7 -. ?To Inst No. I .Dispjrus'mnt Program Inlt'Dats 7 "?ats Days; 1% interest FederaLShare To ED 154.00 6/1512009 311519012 003 3.00% 3 154.00 . - 10 350.00 rant 9l8f2010 3H 12 554 1.00% 5 .00 31.20 - Appendix Total Ineligible Campus-Based Amounts Spent {from FISAP, Part VI. Section B) Federal FWS Federal SEOG Federal Perkins Total C-B Spent ACA Percentage Pelt ACG SMART TEACH FWS FSEOG Perkins Match Match I Match Perkins-No Match Total Campus-Based Total Federal Share 99 T6614 - -- iix?Iir?y? I Is - Is I-J Totals ACA Liability Interest Breakdown Pell Grants ACG SMART TEACH FWS FSEOG Perkins Match Match Match Perkins-No Match ACA Breakdown FWS FSEOG Perkins Match Match Match Perkins-No Match 1,246.75 1 46.75 5 Total Campus?Based $8,504.00? Total Ineligible Campus-Based Amounts Spent (from Part VI, Section B) Federal FWS Federal SEOG Federal Perkins Total C-BSpent ACA Percentage Total Pell ACG - SMART TEACH FWS FSEOG Perkins Match Match Match Perkins-No Match 8 504.00 3 Federal Share 15-31;: . Appendix Totals ACA Liability Interest Breakdown Pell Grants ACG . SMART TEACH FWS FSEOG Perkins Match Match Match Perkins-No-Match ACA Breakdown FWS FSEOG Perkins Match Match Match Perkins-No Match Southern Technical OPE 03903500 (20] 140427638 Appendix Estimated Actual Loss Formula The Estimated Actual Loss Formula (EALF) is used for only certain types of ?ndings on ineligible FFEL and Direct Loan liabilities. The EALF estimates (1) the principal amount that has or will default; and (2) the interest and special allowance on the entire ineligible loan amount. The EALF uses an institution?s applicable cohort default rate (CDR) to estimate the amount of defaults from the ineligible principal amount. This is usually the institution?s latest published CDR. Draft CDRS are not used unless there is no prior CDR. Example: Ineligible Principal Loan Amount $100,000 Cohort Default Rate 10.0% Estimated Default Amount Due 10,000 The EALF calculates interest and special allowance (SA), where applicable, on the entire amount of ineligible loan principal. The number of days used to calculate interest and special allowance is based on average historical data for 1rarious time periods for different types of schools. Period School Type OneuYear Two-Year Four-Year Rate Types Disbursement to Repayment 584 774 969 Interest dc SA Repayment to Default 418 498 619 SA Repayment to Paid In Fall 1659 1530 1712 - SA The EALF uses the actual interest rates in effect when the ineligible loans were disbursed and an annualized average of the quarterly special allowance rates in effect. The EALF divides the number of days in each time period so that changes in interest and special allowance rates are considered. The - EALF also assumes that the ineligible loans were made in two disbursements after a 30-day delay. Example for the Disbursement to Repayment Period for a Two-Year Institution (2004-05) Variable Rate Ineligible Loans: $40,000 subsidized and $60,000 unsubsidized' Interest Rates: 04-05 (2.77), 05-06 (4.70), 06-07Ir (6.54) SA Rates: 04-05 (1.45), 05-06 (1.55), 06-07 (0.53) Subsidized Loan Amount (Interest and Special Allowance) $40,000:? it (451 (0422865)) $40,000l2 (730 (0625865)) 1040,0008 (367 (0707865)) $4,964.61 Unsubsidized Loan Amount (Special Allowance Only) $603008 x- (451 (0145865)) - 3360,0008 (730 (0155865)) $60,000:? it (367 (0053865)) $1,627.36 Appendix Southern Technical College OPE 03903500 201140427638 Appendix Finding #2 Estimated Actual Loss Calculation . Southern Technical College OPE ID #03903500 PRCN #201140427638 Page 1 Appendix Estimated Actual Loss Worksheet Name of Institution Southern Technical College 1. Select Type Two?Year 2. Select Award Year 1 2008-09 3. Enter Cohort Default Rate 3.2% andfor Perkins Default Rate 4. Enter Ineligible Principal Ineligible Principal Estimated Defaults a. BL Subsidized 3,500.00 112.00 b. DL Unsubsidized 5,850.00 187.20 c. FFEL Subsidized - d. FFELUnsubsidized - e. PLUS (DL, FFEL) - f. Perkins - Disb to Repayment 774 Repayment to Default 498 Repayment to PIF 1580 Estimated Actual Loss Disb to Repayment interest and Special DL Subsidized 404.91 Allowance Breakdown FFEL Sub - FFEL Unsub - Repayment to Default FFEL Subsidized - FFEL Unsub - Repayment to HP FFEL Subsidized - FFEL Unsub - Perkins Interest - - Totals - Estimated Actual DL Subsidized 516.91 Loss By Program DL Unsubsidized 187.20 (including interest and FFEL Subsidized - Special Allowance) FFEL Unsub - PLUS (DL, FFEL) - Perkins - Total Estimated Actual Loss Liability 704.1 The "Total Estimated Liability" shown on this worksheet is the Department's estimate of the "actual loss? to the Department that has or will result from the ineligible FFEL and Direct Loan program loans made by your institution. Estimated defaults are calculated using the most appropriate cohort default rate published by the Department. The Department's loss for excess subsidies paid to lenders for ineligible loans is estimated by using the average number of days from: - disbursement to entering repayment. repayment to default. and - repayment to paid-in?full. The averages used are from historical information supplied to the Department from all guarantee agencies. Southern Technical College OPE ID #03903500 PRCN #201 1404217838 Page 2 Appendix Estimated Actual Loss Worksheet Name of Institution Select Type 2. Select Award Year 3. Enter Cohort Default Rate andlor Perkins Default Rate Southern Technical College Two-Year 2009-10 13.3% 4. Enter Ineligible Principal Ineligible Principal Estimated Defaults a. BL Subsidized 4,500.00 598.50 b. DL Unsubsidized 6,000.00 798.00 c. FFEL Subsidized - d. FFEL Unsubsidized - e. PLUS (DL, FFEL) - f. Perkins - Disb to Repayment 774 Repayment to Default 498 Repayment to PIF 1580 Estimated Actual Loss Dish to Repayment lnterest and Special 7 DL Subsidized 435.11 Allowance Breakdown FFEL Sub - FFEL Unsub - Repayment to Default FFEL Subsidized - FF EL Unsub Repayment to' PIF FF EL Subsidized - FF EL Unsub - Perkins Interest - Totals - Estimated Actual DL Subsidized 1,033.61 Loss By Program DL Unsubsidized 798.00 (lncluding lnterest and FFEL Subsidized - Special Allowance) FFEL Unsub - PLUS (DL. FFEL) - Perkins - Total Estimated Actual Loss Liability 1,831.61 The "Total Estimated Liability" shown on this worksheet is the Department's eatimate of the ?actual loss? to the Department that has or will result from the ineligible FFEL and Direct Loan program loans made by your institution. Estimated defaults are calculated using the most appropriate cohort default rate pubiished by the Department. The Department's loss for excess subsidies paid to lenders for ineligible loans is estimated by using the average number of days from: - disbursement to entering repayment. - repayment to default, and - repayment to paid-in?fuil. The averages used are from historical information supplied to the Department from all guarantee agencies. Southern Technical College OPE 03903500. 201140427638 Appendix Finding #5 200919010 File Review 2009/2010 Student Name Previous Correct Enrollment STC 2009-10 SST SAMPLE SST Enrollmen Status 2009-10 PELL TOTAL PELLTOTAL Awardin Status 03 2009-10 Errors? $3,557.00 $3,122.00 no Full Time Half Time $2,905.80 $2,676.00 Yes FuliTime 3/4 Time $7,134.00 $6,630.00 Yes Full Time 3/4. Time $1,704.00 $1,338.00 Yes Full Time 3/4 Time $1,734.00 $1,338.00 Yes Full Time Half Time $1,594.48 $892.00 Yes Full-Time Full Time $3,567.00 $3,122.00 Yes Full Time 3/4 Time $3,567.00 $3,122.00 Yes Full Time Less Than 1/2 Time $1,784.00 $446.00 Yes Full Time 3/4 Time $5,350.00 1 $4,905.00 Yes Full Time 3/4 Time $5,350.00 $4,305.00 Yes Full Time 3/4 Time $1,784.00 $1,338.00 Yes Full Time 3/4 Time $1,784.00 $1,333.00 Yes Full Time 3/4 Time $5,350.00 $4,905.00 Yes Full Time Less Than 1/2 Time $5,350.00 $4,012.00 Yes Full Time 3/4 Time $1,784.00 $1,338.00 Yes Full Time 3/4 Time $3,567.00 $3,121.25 Yes Full Time 3/4 Time $7,334.00 $6,683.00 - Yes Full Time 3/4 Time $5,350.00 $4,904.00 Yes Full Time 3/4 Time $3,557.00 $3,121.00 Yes Full Time Less Than 1/2 Time $7,134.00 $5,746.00 Yes Full Time Full Time $3,557.00 $2,575.00 Yes Full Time 3/4 Time $3,567.00 $3,121.00 Yes Full Time - 3/4 Time $5,350.00 $4,755.00 Yes . Full Time 3/4. Time $5,350.00 $4,904.00 Yes Full Time 3/4 Time $5,350.00 $4,904.00 Yes Full Time 3/4 Time $7,134.00 $6,638.00 Yes Full Time 3/4 Time $5,350.00 $4,304.00 - Yes Full Time Half Time $5,350.00 $4,155.00 Yes Full Time Half Time $5,350.00 $4,459.00 Yes Full Time Full Time $5,350.00 $5,201.00 Yes Full Time Full Time' $5,350.00 - $4,755.00 Yes Finding #5 Pell Underpayments/Overpaymerits Appendix Award Year 2009-10 BOTH 2009- 10 2009- 10 2009-10 2009-10 BOTH 2009?10 2009-10 2009-10 2009-10 2009-10 BOTH 2009-10 2009-10 2009-10 BOTH BOTH 2009-10 BOTH BOTH BOTH 2009-10 BOTH BOTH BOTH BOTH BOTH 2009-10 2009-10 2009-10 59 SAMPLE PELL LIABILITY $445.00 $305.30 $445.00 $443.00 $445.00 $702.43 $445.00 $445.00 . $1,338.00 $445.00 $445.00 $445.00 $443.00 $445.00 $1,333.00 $445.00- $445.75 - $1,145.00 $446.00 $443.00 $1,533.00 $392.00 $443.00 . $595.00 $446.00 $445.00 $440.00 $440.00 $595.00 $331.00 $143.00 $535.00 Finding #5 Pell Uriderpayments/Dverpavments 200912010 34 (WW3) Full, Time Half Time $7,134.00 $6,242.00 35 Full Time 314 Time $7,134.00 $6,688.00 33 Full Time 314 Time 7 $3,567.00 . $3,121.00 37 Full Time 314 Time $5,200.00 7 $4,375.00 38 FUII Time Less Than 11' 2 Time $3,567.00 $2,229.00 - 39 Full Time 314 Time $3,567.00 $3,121.00 40 Full Time 314 Time $5,350.00 $4,904.00 41 Full Time 314 Time $7,134.00 $6,633.00 42 Full Time Full Time $7,134.00 $6,633.00 43 Full Time 314 Time $7,134.00 - $6,633.00 44 Full Time Full Time $5,350.00 $5,201.00 45 Full Time 314 Time $1,367.00 $1,750.00 46 Full Time 314 Time $7,134.00 $5,350.00 47 Full Time Half Time $1,900.00 $1,534.00 43 Fuli Time Fuli Time $7,134.00 $6,533.00 49 Full Time 314 Time $3,567.00 $3,121.00 50 Full Time Full Time 7 $7,134.00 $6,633.00 51 Full Time 314 Time $7,134.00 $6,633.00 52 Full Time 314 Time $7,134.00 $6,242.00 53 Full Time 314 Time $7,134.00 $6,633.00 54 Fuli Time 314 Time $5,350.00 $4,904.00 55 Full Time Less Than 112 Time $1,333.00 $1,083.00 56 Fuii Time Half Time $4,393.12 $3,306.12 57 Full Time 314 Time $7,134.00 $6,688.00 53 Full Time 314 Time $7,134.00 $6,633.00 59 Full Time Fuil Time $5,350.00 $5,201.00 60 Full Time Half Time $5,350.00 $4,453.00 61 Fuli Time 314 Time $5,350.00 $4,012.00 62 Full Time 314 Time $7,134.00 $6,633.00 63 Full Time Half Time $5,350.00 $4,458.00 64 Full Time 314 Time $5,350.00 $4,904.00 Full Time 314 Time $7,134.00 $6,539.00 Full Time 314'Time $3,567.00 $3,121.00 Full! Time 314 Time $7,134.00 $6,539.00 Full Time 314 Time $5,350.00 $4,904.00 Full Time 314 Time $3,567.00 $3,121.00 'Appendix Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes - Yes Yes Yes Yes Yes Yes Yes Yes 7 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes 2009-10 BOTH BOTH BOTH BOTH 2009-10 2009-10 2009?10 30TH 2009-10 2009-10 BOTH BOTH 2009-10 30TH BOTH BOTH BOTH BOTH 2009-10 2009-10 BOTH 2009-10 BOTH 2009-10 - 2009-10 2009-10 2009-10 2009-10 2009-10 2009-10 2009210 2009-10 2009-10 2009~10 2009-10 $392.00 $443.00 $446.00 $325.00 $1,333.00 $446.00 $443.00 $443.00 $443.00 $446.00 $149.00 $117.00 - $1,734.00 $316.00 $445.00 $446.00 -- $446.00 $446.00 $392.00 $443.00 $446.00 $250.00 $392.00 $446.00 $445.00 $149.00 $392.00 $1,333.00 $446.00 $392.00 $443.00. $595.00 $446.00 $595.00 $446.00 $446.00 Finding #5 Fall Underpaymentleverpayments 2009ir 2010 Full Time Half Time $5,350.00 $4,458.00 Full Time Half Time $3,567.00 $2,377.00 Full Time Full Time $3,567.00 $3,121.00 Full Time 3M Time $7,134.00 $6,638.00 Full Time Full Time $5,350.00 $4,904.00 Full Time 3} 4 Time $7,134.00 $6,688.00 Full Time 3f4 Time $7,134.00 $6,688.00 Full Time 3} 4 Time $7,134.00 $6,539.00 Full Time Time $7,133.00 $6,688.00 Full Time 31'4 Time $7,134.00 $6,688.00 Full Time 314 Time $5,350.00 $4,904.00 Full Time 3/4 Time $7,134.00 $6,688.00 Fuil Time Half Time $5,350.00 $4,458.00 Full Time 3M Time $7,134.00 $6,688.00 Full Time . 3/4 Time $5,350.00 $4,904.00 Full Time Half Time $1,784.00 $892.00 Full Time 32'4 Time $3,567.00 $2,972.00 Full Time 3,04 $1,850.00 $1,337.50 Appendix Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes 2009?10 2009-10 BOTH BOTH BOTH 2009-10 2009.10 2009-10 BOTH 2009-10 BOTH 2009-10 2009-10 2009-10 200940 2009-10 1200940 539200 $1,190.00 $44e00 $446.00 544e00 $44900 $44e00 $595.00 $445.00 $44500 $44500 s44e00 $892.00 $445.00 $445.00 $992.00 $595.00 545250 $49,512.53 Southern Technical College OPE 03903500 201140427633 Appendix I Finding #5 201012011 File Review Finding #5 Peil Underpayment/Overpayments 2010/2011 Student Name SSN Previous Enroitment Correct Enrollment 511.: 2010-11 SST SAMPLE Status 2010?11 Status 2010-11 PELL TOTAL PELL TOTAL 314 Time 314 Time $3,297.50 $9,199.00 Full Time Half Time $1,545.62 $925.00 Full Time 9/4 Time $1,350.00 $1,933.00 Full Time Less Than 1/2 Time $1,545.52 $1,082.62 Full Time 3/4 Time $1,350.00 $1,330.00 Full Time Full Time $5,550.00 $5,088.00 Full Time Half Time $3,210.27 $2,775.00 Fuii Time Less Than 1/2 Time $940.17 $462.00 Full Time Half Time $1,850.00 $925.00 $3,700.00 $3,080.00 Full Time ?3/4 Time $7,400.00 $6,938.00 Full Time Less Than 1/2 Time $3,210.54 $2,312.00 Full Time 3/4 Time $3,700.00 $3,238.00 Full Time 3/4 Time $1,850.00 $1,388.00 Full Time Less Than 1/2 Time $571.65 $462.00 Full Time Full Time $5,550.00 $5,088.00 Fuii Time 3/4 Time $1,850.00 $1,388.00 Full Time 3/4 Time $1,850.00 $1,388.00 Full Time Full Time $2,467.00 $1,850.00 Full Time Half Time $1,545.62 592500 Full Time Half Time $3,237.50 $2,775.00 Full Time 3/4 Time $6,167.00 $5,396.00 Fuii Time Half Time $3,083.00 $2,020.00 Fuil Time 3/4 Time $3,700.00 $3,546.00 Full Time 3/4 Time $5,550.00 $4,471.00 Full Time 3/4 Time $7,400.00 $6,938.00 Full Time 3/4 Time $0,376.03 $5,014.03 Full Time 3/4 Time $7,400.00 $6,938.00 Fuli Time Less Than 1/2 Time $2,407.00 $1,850.00 Half Time 3/4 Time $3,083.00 $2,621.00 Fuil Tlme Less Than 1/2 Time $4,934.00 . $3,855.00 Full Time 3/4 Time $3,700.00 $3,083.00 Full Time 3/4 Time $1,850.00 $1,388.00 Full Time Full Time $5,550.00 $3,287.00 Full Time 3/4 Time $3,600.00 $3,300.00 Full Time 3/4 Tlme $7,400.00 $6,937.00 Appendix'l 55T Awarding ErrorsYes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Award Year 20 10-1 1 2010?11 2010-11 2010?11 2010-11 2010-11 2010-11 2010-11 2010-11 BOTH 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-1 1 80TH 2010-11 BOTH 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 BOTH 2010-11 BOTH 2010-11 2010-11 SST SAMPLE PELL LIABILITY $99.50 $620.62 $462.00 $463.00 $462.00 $462.00 $435.27 $473.17 $925.00 $620.00 $462.00 $898.54 $462.00 $462.00 $109.65 $462.00 $462.00 $462.00 $617.00 $620.52 $462.50 $771.00 $453.00 $154.00 $1,079.00 $462.00 $562.00 $462.00 $617.00 $462.00 $1,079.00 $617.00 $462.00 $2,263.00 $300.00 $463.00 Pell 'Underpaymenthyerpeyments Finding #5 2 1npn1 1 FUN Time 3f4 Time $3,700.00 $3,033.00 Full Time Half Time $1,850.00 $611.00 Full Time 3M Time $1,233.00 $1,080.00 Full Time Bid Time $7,400.00 $6,933.00 Full Time Half Time $6,278.15 $5,353.75 Full Time Less Than 11'? Time $5,550.00 $4,311.00 Full Time 31,4 Time $3,700.00 4 $3,254.00 Full Time 3/91 Time $7,400.00 $6,012.00 Full Time 31'4 Time $7,400.00 $5,931.00 Half Time Less Than 1f2 Time $2,775.00 $2,457.00 Full Time 3f4 Time $5,550.00 $4,933.00 Full Time Half Time $5,087.50 $4,762.50 Full Time Half Time $7,400.00 $6,475.00 Full Time Half Time $4,625.00 $4,311.00 3/4 Time Half Time $6,937.50 $6,475.00 Full Time Half Time $4,162.50 $2.17 5.00 Appendix Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes 'Yes BOTH BOTH 2010-11 2010-11 2010-11 BOTH 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 2010-11 BOTH $617.00 $1,233.00 $153.00 $452.00 $925.00 $1,233.00 $440.00 $1,330.00 $403.00 $300.00 5617.00 $325.00 $925.00 $303.00 $452.50 $1,382.50 $31,925.32 Southern Technical College OPE 03903500 201140427638 Appendix Finding #5 Cost of Funds Ineligible Disbursements (Non-Loan) - Cost of Funds and Administrative Cost Allowance Name of Institution: No. Descriptionihlame 20091'2010 2010:2011 Total Ineligible Federal FWS Federal SEOG Federal Perkins Total Spent ACA Percentage Pell ACG SMART TEACH FWS FSEOG Perkins Match Match Match Perkins-No Match Total Campus-Based Southern Technical College: Finding #5 Ineligible I Program? $49 612.53 Pell Grant 31976.87 Pell Grant $81,589.40 Campus-Based Amounts Spent (from FISAP, Part VI, Section B) Total Federal Share 31.589.1nt Date" . Date 630/2010 6130.001 1 311512012 Appendix No; of Days 624 259 CVFR or? Interest 100% 49 612.53 Federal Share 1.00% 3197030? Totals ACA Liability Interest Breakdown Pell Grants ACG SMART TEACH FWS FSEOG Perkins Match Match Match Perkins?No Match ACA Breakdown FWS FSEOG Perkins Match Match Match Perkins-No Match To an 343.17 225.90 To Inst Accounts 55 1.0?50? 5 1 075.07 Southern Technical College OPE 03903500 201140427638 . Appendix Finding #5 200912010 Less Than 1/2 Time HP HO Finding #5 Underpayment/Overpayment 2009/2010 {Student Less Than 1/2 Time) Student Name SSN Previous Enrollment Correct Sub Unsub Status 2009-10 Enrollment Status 2009?10 Full Time Less Than 1/2 Time $0.00 $0.00 Full Time Less Than 1/2 Time $0.00 $2,825.00 Full Time Less Than 1/2 Time $3,884.00 $6,000.00 Full Time Less Than 1/2 Time $0.00 $0.00 Full Time Less Than 1/2 Time $0.00 $0.00 Full Time Less Than 1/2 Time $3,500.00 $6,000.00 Full Time Less Than 1/2 Time $3,500.00 $6,000.00 Full Time Less Than 1/2 Time $0.00 $0.00 Full Time Less Than 1/2 Time $8,000.00 $12,000.00 Full Time Less Than 1/2 Time $0.00 $0.00 Full Time Less Than 1/2 Time $3,500.00 $6,000.00 $22,334.00 $38,825.00 Appendix Southern Technical College OPE 03903500 201140427638 Appendix Finding #5 20101201 1 Less Than V2 Time Finding #5 - Underpaymenthverpayment 201012011 (Student Less Than 1f2 Time) Appendix Student Name Previous Enrollment . correct Sub Unsub Status 2010-11 Enrollment Status . 2010-11 1 (mmc) Full Time Less Than 1/2 Time $0.00 $0.00 2 Full Time Less Than 1/2 Time $0.00 $0.00 3 Full Time Less Than 1/2 Time $4,667.00 $8,000.00 4 Full Time Less Than 1/2 Time $0.00 $0.00 5 Full Time Less Than 1/2 Time $1,167.00 $2,000.00 6 Full Time Less Than 1/2 Time $0.00 $0.00 7 Full Time Less Than 1/2 Time $0.00 $0.00 8 Full Time Less Than 1/2 Time $4,500.00 $5,676.00 9 Full Time Less Than 1/2 Time $750.00 $2,037.00 10 Full Time Less Than 1/2 Time $3,500.00 $6,000.00 11 Full Time Less Than 1/2 Time $0.00 $512.00 12 Full Time Less Than 1/2 Time $0.00 $0.00 13 Full Time 7 Less Than 1/2 Time 7 $3,600.00 $3,678.00 14 Full Time . Less Than 1/2 Time $3,750.00 $2,611.00 15 Full Time Less Than 1/2 Time $4,500.00 $6,000.00 16 Full Time Less Than 1/2 Time $3,833.00 $5,884.00 17 Less Than 112 Time Less Than 1/ 2 Time $3,088.00 $4,000.00 13 Full Time Less Than 1/2 Time - $4,500.00 $2,000.00 19 Full Time Less Than 1/2 Time $4,500.00 $5,800.00 20 Full Time Less Than 1/2 Time $3,915.00 $5,300.00 21 Full Time Less Than 1/2 Time $2,333.00 $0.00 22 Half Time . Less Than 1/2 Time $152.00 $0.00 23 Fuli Time Less Than 1/2 Time $600.00 $800.00 24 Full Time Less Than 1/2 Time $0.00 $0.00 '25 Full Time Less Than 1/2 Time $6,833.00 $10,000.00 26 Full Time Less Than 1/2 Time $0.00 $0.00 $55,248.00 Southern Technical College OPE 03903500 201140427638 Appendix Finding #5 Estimated Actual Loss Calculation Southern Technical College OPE ID #03903500 PRCN #20114042Tl338 Page 1 Appendix Estimated Actual Loss Worksheet Name of Institution Southern Technical College 1. Select Type Two-Year 2. Select Award Year 2009?10 3. Enter Cohort Default Rate 13.3% andfor Perkins Default Rate 4. Enter Ineligible Principal Ineligible Principal Estimated Defaults a. UL Subsidized 22.38400 2,977.07 b. DL Unsubsidized 38.82500 35 5,163.73 0. FFEL Subsidized - d. FFEL Unsubsidized - e. PLUS (DL, FFEL) - Perkins - Disb to Repayment T74 Repayment to Default 498 Repayment to PIF 1580 Estimated Actual Loss Disb to Repayment Interest and Special DL Subsidized 5 2.16431 Allowance Breakdown FFEL Sub - FFEL Unsub - Repayment to Default FFEL Subsidized - FFEL Unsub - Repayment to PIF FFEL Subsidized - FFEL Unsub - Perkins Interest - Totals - Estimated Actual DL Subsidized - 5,141.38 .Loss By Program DL Unsubsidized 5,163.73 (Including Interest and FFEL Subsidized - - SpecialAilowance) - PLUS (DL, FFEL) - Perkins - Total Estimated Actual Loss Liability 10,305.11 The "Total Estimated Liability" shown on this worksheet is the Department's estimate of the "actual loss? to the Department that has or will result from the ineligible FFEL and Direct Loan program loans made by your institution. Estimated defaults are calculated using the most appropriate cohort default rate published by the Department. The Department's loss for excess subsidies paid to lenders for ineligible loans is estimated by using the average number of days from: - disbursement to entering repayment, - repayment to default. and - repayment to paid?in?tull. The averages used are from historical information supplied to the Department from all guarantee agencies. Southern Technical College OPE ID #03903500 PRCN #201140427638 Page 2 Appendix Estimated Actual Loss Worksheet Name of institution Southern Technical College 1. Select Type Two?Year 2. Select Award Year 2010-11 3. Enter Cohort Default Rate 15.0% andi'or Perkins Default Rate 4. Enter Ineligible Principal Ineligible Principal Estimated Defaults a. UL Subsidized 56,248.00 8,437.20 b. DL Unsubsidized 70,298.00 10,544.70 c. FFEL Subsidized - d. FFEL Unsubsidized - e. PLUS (DL, FFEL) - f. Perkins - Disb to Repayment 7'l4 Repayment to Default 498 Repayment to PIF 1580 Estimated Actual Loss Disb to Repayment lnterest and Special DL Subsidized 4,4316? Allowance Breakdown FFEL Sub - FFEL Unsub . - Repayment to Default. FFEL Subsidized - FFEL Unsub - Repayment to PIF FFEL Subsidized - FFEL Unsub Perkins interest - Totals - Estimated Actual DL Subsidized 12,824.87 Loss By Program DL Unsubsidized 7 (including Interest and FFEL Subsidized 96 Special Allowance) FFEL Unsub - PLUS (DL, FFEL) Perkins - Total Estimated'Actual Loss Liability I 23,419.57 The "Total Estimated Liability? shown on this worksheet is the Department's estimate of the "actual loss? to the Department that has or will result from the ineligible FFEL and Direct Loan program loans made by your institution. Estimated defaults are calculated using the most appropriate cohort default rate published by the Department. The Department?s loss for excess subsidies paid to lenders for ineligible loans is estimated by using the average number of days from: - disbursement to entering repayment, - repayment to default, and - repayment to paid?in?full. The averages used are from historical information supplied to the Department from all guarantee agencies. Final Program Review Determination PRCN 201140427638 Appendix Response to the Program Review Report . 00 3940 DEAN ROAD ORMNDO, FL 32317 7 ll?, PHONE: 407-671-9922 6 FAX 407-671-9790 a (If??l?f?l ??ijl?u'f June 11,2012 Ms. Pat Gilert Atlanta Case Team U. S. Department of EducatioanSA 61 Street, S.W Room 18T40 Atlanta, GA 30303-3104 RE: Program Review Report OPE ID: 03903500 PRCN: 201140427638 Dear Ms. Gilbert: Attached, please ?nd the written responses to the'?ndings included in the Program Review Report for Southern Technical College (OPE dated March 15, 2012. In compliance with the instructions accompanying the Report, the College has formulated a narrative response to each ?nding, which is accompanied with support documentation when applicable. - In addition, the College performed two (2) substantial ?le reviews in response to Finding #1 and Finding The College developed electronic spreadsheets containing the results of the reviews. Those spreadsheets along with supporting documentation were reviewed and audited by the IPA engaged for that purpose in accordance with the protocol submitted to and approved by the Department. The electronic Spreadsheets, along with the auditor?s report and documentation, are submitted as part of this response. Please note that the supporting documentation for the ?le reviews is being submitted in electronic format. If you would prefer a hardcopy version of the documentation, the College is prepared to forward the printed documents to your attention. - The narrative responses should be complete and self-explanatory as submitted. However, should you have any questions, I can be contacted via telephone at (407) 323-4141 andfor via e?mail at iguliano??southemtechedu. Shearer, (If i John D. Euliano President Enclosures Finding #1 Con?icting Information Citation: "The ability of an institution to coordinate the information it collects and to resolve discrepancies are critical elements in an evaluation of its administrative capability. Regulations require institutions to develop an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student?s application for financial aid under Title iv; HEA programs. 34 C. F.R. ?668.16 and Noncompliance: TC failed to resolve the discrepant information for the below students: Student The FAFSA signed on 11/6/2009 shows the student as single. Leave of Absence paperwork dated 4/5/2010 and 11/22/2010 shows the student?s reason for the 10.4 as ?separation? with spouse. . Student #16: The student was not selected for veri?cation; however, the student had a code that needed to be resolved and the institution should have resolved the discrepant information. The enrollment application shows the student as married. The student reported Isingle on the FAFSA and reported only his income. The household size was reported as 3. Student #22: The student was not selected for verification. However, the student has a code that needed to be resolved and the institution should have resolved the discrepant information. Enrollment agreement 'and verification worksheet show ?married? and the FAFSA reported ?single?. incorrect status of T?Head of Household? used on tax form 1040. i code for Selective Service was not resolved. Student #25: 'The student was not selected for verification for the 2010/2011 award year but was selected for the 2009/2010 award year. The enrollment agreement shows the student as a single male and the student answered ?no? to the question on enrollment agreement regarding are you a single parent. The student?s FAFSA reported 2 in household size and on the veri?cation worksheet for 2009/2010. The student also ?led an amended tax return for 2008 changing the filing status as ?single? rather than "head of household?. - - - Student #28: The student was not selected for verification. However, the enrollment agreement - shows the student as single male and not a single parent. The FAFSA shows 2 in household size and the student answered ?yes? to the question regarding children you support. Required Actiont The program review was conducted due to several complaints from male students that they were being directed by officials at STC to report dependents when in fact they were not providing over 50% support. The discrepant information for the students identi?ed above reveals questionable information reported on the FAFSA and the enrollment agreement. in response to this ?nding, STC must resolve the discrepant information for the students listed above and provide supporting documentation. STC must also conduct a ?le review of all the students for the 2009/2010 and 2010/2011 award years to determine if corrections to the household size would result in a change to the Estimated Family Contribution where there is conflicting information regarding household size and answers given by the student on either the FAFSA or institution '5 nrollmentAgreement. Please include the results of the file review via diskette or in an electronic spreadsheet, containing the following information: - Revised Title IV aid entitlement ineligible award amounts and refunds due to the Title iv programs 1. Student?s name and Social Security Number {last 4 digits only} 2. Award Year . 3. Original EFC 4. Title I aid disbursed 5. Revised EFC 6. 7. In lieu of performing a ?le review for the entire population (1504) for 2009/2010 and {1830) for the 2010/2011 award year to determine actual liabilities, STC has the option of performing this file review for only the remainder of the statistical sample not tested by the Department during the program review (308 for 2009/2010 320 Jfor 2010/2011 remaining in the statistical samples). The results from this ?le review using the statistical sample will be used to project liabilities for the entire population the average liability for the recipients in the statistical sample will be multiplied by the total population). This option is intended to reduce the burden on the . institution of conducting the full file review. if STC wishes to select this option, please use the attached statistical sample listings for award years 2009/2010 and 2010/2011 (Appendix and C) for this finding. File reviews must be performed for all students on each statistical sample list except those included in Appendix A of this Program Review Report for the respective award year. If STC elects to do the full file review, it is recommended that STC?rst review the remainder of the students in the statistical sample. At that point, STC may decide to accept liability projection instead of continuing with a full file review. STC must engage an independent Public Accountant to test the ?le review completed by STC. The must develop a set of procedures designed for testing the accuracy and completeness of the file review. The suggested procedures must be provided to Pat Gilbert within 30 days of the institution?s receipt of this Program Review Report. Pat Gilbert'will review the procedures, indicate if any changes are needed, and approve the procedures. The IPA must apply the Agreed Upon Procedures to test the ?le review completed by STC, and prepare a report including any exceptions noted during its testing. The exceptions must be detailed and identified. Exceptions must be reported for all ?le review elements as speci?ed in the ?nding requirement as presented in the Program Review Report. The lPA's report must be submitted with STCs response to this Program Review Report. Payment instructions for any determined liability will be provided in the Final Program Review Determination Letter.? Narrative Response: ST has completed its review of the remaining students in the statistical samples for the 200912010 and 201012011 award years. The required electronic spreadsheet and the IPA testlreport is included with this response. Regarding the students speci?cally referred to in the ?nding, the following information applies: Student All of the information provided by the student is consistent and indicates that the student is single. The LOA references in the student's academic file (as distinct from the ?nancial aid ?le) were completed and placed in the ?le by the Registrar and reflect only the Registrar?s perception of the situation. The use of the term "spouse" was done so at the discretion of the Registrar and is not of?cial information provided by the student or by a third party/agency in reference to the student's marital status. In the absence of information provided by the student or by a third partyfagency that would possess such information, there is no conflicting data in the student's ?le. . Student #16: The student provided a letter clarifying that he is single and never married. This statement resolves the discrepant information and results in no change to the student's EFC. Student #22: The College agrees with the ?nding Concerning this student and the discrepant information has not been resolved. However, the College has recalculated the student?s entitlement by reducing the size of the household. This resulted in no change to the student?s EFC and Title IV eligibility. This information is available in the electronic spreadsheet provided with this response. Student #25: I The student correctly completed the information on the enrollment agreement. He indicates that he is not a single parent, and that he is not married. At the time he completed the enrollment agreement and ?nancial aid paperwork he was living with his ?ance and their child. The FAFSA was correctly completed, indicating 2 people in the household size (the student and his child), and leaving the ?ance out. Therefore, there was no change in the EFC. Student #28: The College agrees with this ?nding and was unable to obtain clari?cation from the student. The College has not re-calculated the EFC because it is not possible to obtain the spouse?s income information. The Independent Public Accountant's report showed that there was a very small percentage of ?les with discrepant information. Out of the population of ?les examined, there was an error rate of only 0.34% of the ?les in the 2009/10 award year and 1.61% of the ?les in the 2010/11 award year. Based on the information above and the IPA report of the audited ?le review, the College believes that there is no materiai pattern of failing to resolve con?icting information 'which may become apparent during the packaging interview or subsequent to that activity. Therefore, the College respectfully requests that the Department make a ?nal determination in this matter and that the??nding be closed. - March 29, 20172 I, I am not married, nor have i ever been married; Sinc?reiv. Finding #2 Incomplete Veri?cation Citation: ?If the Central Processing System (CPS) selects an application for veri?cation, an institution must verify five major data elements {household size, number enrolled in college, adjusted gross income (AGI), and U5. income tax paid by getting a copy of the signed 0.5. income tax return. If a copy of the tax return is not available, the student must instead submit a copy of any IRS form that lists tax information and provides the information needed for verification. The form Ms; be signed by the student unless the tits sent the form directly to the school. 34 C. ER. 668.56 668.5 7? - Noncompliancez. ?Student #10 was selected for veri?cation for the 2008/2009 award year.- The FASFA shows the student as married. The student?s ?ling status on the 2008 tax return shows "head of household?, this is an incorrect ?ling status. The student was disbursed Peil funds in the amount of $3154, subsidized loans of $3500 and unsubsidized loans of 55350. For the 2009/2010 award year, the student was not selected for veri?cation. The student was disbursed Pell funds in the amount of $5350, subsidized loans of $4500 and unsubsidized loans of $6000.? . Required Action: must obtain the proper tax forms to compiete the verification process. Failure to obtain the correct tax documents will resuit in a liability for the Jfunds . disbursed.? Narrative Response: Southern Technical College'concurs with the Finding and is unable to provide the required corrected tax document. The College awaits the Department?s determination of any liability. Finding #3 Dependency Override Not Properly Documented Citation: he Higher Education Act allows an aid administrator to make dependency overrides on a case-by?case basis for students with unusual circumstances. if the administrator judges that an override is appropriate, he/she must document the unusual circumstances. However, none of the conditions listed below, singly or in conjunction, qualify as unusual circumstances or merit _a dependency override: HEA 480(d)( 7) Parents refuse to contribute to the student?s education Parents are unwilling to provide information on the application or for verification; Parents do not claim the student as a dependent for income tax purposes; Student demonstrates total sel?su?iciency. If the financial aid administrators use professional judgment, the adjustment must be based on a student?s individual circumstances and must be documented in the student?s file. The documentation supporting the override must be adequate. There should be supplementary information supporting the finding of an unusual circumstance necessitating the dependency override. The school is held accountable for all professional judgments make and each decision must be fully documented. So, although the Department will not secondwguess the Financial Aid Administrator; there is a baseline of reasonableness that any professional judgment should meet, as well as, the requirement that the reason be adequately documented.? Noncompliance: used Professional Judgment to make student #19 {20 years old) on Independent student based on the statement that he provided more than 50% of his girlfriend?s (20 years old) support for the year with only $3,908 in income. Dependency Override can?t be used to waive general student eligibility requirements or to circumvent the intent of the law or regulations.? Required Action: he institution must provide a statement from the girlfriend regarding the amount of income she receives and the amount of support provided by the student on her behalf. Narrative Response: The College understands the citation relative to HEA ?480ldjl7j and does not concur with the ?nding. The College determined that the student was independent basedon the information provided to the College by the applicant and his girlfriend, which indicated that the applicant provided more than 50% of the support for the girlfriend. Based upon that information the College never considered the applicant to be dependent and, therefore, no override was required. Because the College relied on con?rmed information to determine that the applicant was an independent student, there was no need to over-ride the dependency status at the time the applicant was initially packaged. The College did not have to exercise professional judgment in determining the applicant?s status and, therefore, is not in violation of HEA The College respectfully requests that this Finding be closed and that no further action be required of the College. From: a? 03f21i2812 17:42 #539 P.001f001 m5 ?Wr%?15 Ma mm gm; rpig? m5 gummy/13 calf demon ?1 Finding #4 Academic Policy Stricter than Satisfactory Academic Policy (SAP) Citation: ?For purposes of determining student eligibility for assistance under a Title IV, HEA program, establishes, publishes, and applies reasonable standards far measuring whether an otherwise eligible student is maintaining satisfactory progress in his/her educational program. The Secretary considers an institution?s standards to be reasonable if the standards are the some as or stricter than the institution?s standards for a student enrolled in the same educational program who is not receiving assistant under a Title iv, HEA program. 34 GER. Noncompliance: "5 TC academic policy is stricter than the Satisfactory Academic Policy (SAP) for students receiving Title iv funding. - Academic Policy "'An student whose GPA falls below 2.0 be placed on academic warning. However, students may not be to further action unless their academic achievement or credit completion rate falls below the satisfactory progress parameters outlined below. Students mgy also be placed on an academic warning if their class attendance falls below 60% for a given course, and. all students seeking re?enroliment as a regular student following a suspension for academic progress will be placed an academic warning; A student on academic warning my be counseled and given assistance, if needed, to improve his/her GPA. . SAP Policy student must meet the following standards of academic achievement and successful course completion while enrolled at 5 TC. Degree Students Diploma Students Credits Minimum Credits Minimum Attempted GPA Attempted GPA 0 23.9 1.00 0 ?23 1.00 24 1.25 24 --42.0 1.50 48 7'13 1.50 43 and Up 2.00 72 89.9 1. 75 so and Up 2.0 ?The following discrepancies were identified in relation to SAP testing. Student "The student?s GPA for the end of Spring 3 was 1.00. The student reenrolled for Summer and the term GPA was 1.20 with a cumulative GPA of 1.56, Full term GPA 0.25 and Cumulative GPA 1.15. The student continued enrollment for Winter 3 and received all F?s and a cumulative GPA of 0.91. Student #16: '?The student was placed on Academic Warning for the Summer term with a cumulative GPA Student #19: - he student term GPA for Fall 3 was 0. The student re-enroiledfor the_Winter 3 term and received 2 F?s and a WP receiving a GPA of 0 and 0 Cumulative GPA of 1.44.? ll Required Action: must utiliae the. Academic Policy in place at the time of the review and conduct a file review {This requirement was waived and STC is required to respond on the students noted in the non-campiiance above. Our narrative addresses those studen ts. Narrative Response: The College believes the reviewers have a fundamental misunderstanding of our academic policy. The College does not publish and/or enforce multiple standards measuring whether a student is maintaining satisfactory progress in his or her educational program. All of the language associated with the satisfactory progress and academic policy standards is inclusive and pertains to all students enrolled at the College- The language referred to in Finding #4 as "Academic Policy" as distinct from Policy? is in fact a subsection of the satisfactory progress standards. it is not a stand-alone policy that is in effect for some, but not all, students. Rather, it is a statement regarding academic counseling that is available to students who have a GPA below 2.0. This counseling is purely informational in nature in that the College informs any student regardless of Title IV eligibility that a_ GPA of less than 2.0 is substandard and needs to be improved. It is important to note that there is no sanction imposed on a student for this status. To the contrary, the "academic" policy speci?cally and clearly states that no other action regarding the student?s status with the College will be forthcoming unless the student?s achievement or credit completion rate falls below the satisfactory progress parameters Therefore, for any student whose GPA is below 2.0 but is otherwise meeting the SAP standards, no action is required on the part of the College. The College may perform counseiing or other actions to help the student improve his or her GPA, but there is no requirement that either the student or the College take any particular steps. With reSpect to each of the students noted as potential violations, the College provides the following information: Student This student was in continuous enrollment during four academic quarters. The review of the student's qualitative SAP at the end of each quarterly evaluation point is as follows: Quarter Start SAP Cumulative Minimum Actual SAP Incorrectly Category Hours Required Cumulative Status Disbursed Attempted Cumulative GPA - Funds GPA Spring 0 - 5/4/2009 Full-time 18.0 1.00 1.00 SAP Met None Summer 3 - 8/3/2009 Full?time 33.0 1.25 1.56 SAP Met None Fall 0 - 10/26/2009 Full-time 51.0 1.50 1.15 Financial None . Aid Warning Winter 2/1/2010 it Time 61.5 1.50 0.91 Student None Dropped This student was'eligibie for Title IV disbursements during all periods of enrollment, although the student had reached a point of ?nancial aid warning after the third evaluation point. The student probably would have merited ?nancial aid suspension at the end of the last quarter. However, the student dropped before that evaluation point was reached, so no further action by the College was necessitated. - - i Student #16: This student was enrolled full-time during each of the academic quarters he attended. The student is actively enrolled in the current quarter and is scheduled for full-time enrollment. The student?s performance in the current quarter cannot be evaluated until all. of the scheduled credits have been attempted. The review of the student's qualitative SAP during the four completed quarters is as follows: Quarter Start SAP Cumulative Minimum Actual SAP Incurrectly. Category Hours Required Cumulative Status Disbursed Attempted Cumulative GPA Funds GPA Winter A - 211012011 Full?time 18.0 1.00 1.67 In SAP None Spring 3 - 51512011 Full-time 33.0 1.25 1.77 In SAP None (The student was given an academic warning at this point, but not a ?nancial aid . . warning} Summer 81312011 Full-time 46.5 1.25 2.03 . . In SAP None Fall 1013112011 Full-time 60.0 1.50 1.95 In Sap None The student was eligible for Title IV disbursements during all periods of enrollment to date. The student?s status will be re-evaluated at the completion of the current quarter which is the next evaluation point. Student #19: This student enrolled full-time in three consecutive quarters before dropping from the College. The review of the student's qualitative SAP is as follows: Quarter Start SAP Cumulative Minimum Actual SAP Incorrectly - Category Hours Cumulative Cumulative StatUs Disbursed Attempted GPA GPA Funds Summer 31212010 Fuil-time 15.0 1.00 3.30 In SAP None Fall 3 - 1012512010 Full-time 28.5 1.25 2.05 in SAP None Winter 8 21112011 Full-time 46.5 1.25 1.44 In SAP None The student was in compliance with SAP requirements throughput the period of his enrollment. The student withdrew from the College during the ?nal course of the third quarter while making satisfactory progress in accordance with the College's published standards. Based upon .the information above and documentation provided, Southern Technical College has no iiability under this ?nding and is in compliancewith the requirements of 34 C.F.R. 668.15ie}. Therefore, the College respectfully requests that Finding #4 be closed with no additional action required of the Coliege. Finally, the Coilege is sensitive to the fact that the "academic" policy meant to provide a warning . to the student concerning a GPA below 2.0 was apparently confused with the actual policy that affects a student?s continued eligibility to receive Title IV fonds. In order to avoid such confusion in the future, the College has eliminated the "academic" polio?r and it no longer appears in any of the College's publications. Finding #5 Pell Underpayment/Overpayment Citation: "if an institution uses credit hours and academic terms to measure a student?s progress, then the student?s enrollment status {full-time, three-quarter time, half-time, or less than half-time__ is used to calculate the amount of the student?s Federal Pell Grant payment. A school may use its own standards for enrollment status, provided the standards meet the minimum requirements de?ne in regulations. 34 C. ER. 690. 63(c)? Noncompliance: he students identified below were overpaid due to their enrollment status: Student Enrolled for 6 hours (1/2 time} for Summer C. The student was disbursed Pell funds in the amount of $1284 for full-time status. The student should have received $891.00. The school returned $189.52 on 11/1/2009 based on the student?s withdrawal. Student Enrolled for 1.5 hours for Winter 8. The student was disbursed $1850 in Pell funds forfull?time enrollment. The student should have only received $1388. Student #12: Enrolled for 9 hours for Summer C. The student was disbursed $1850 in Pell funds forfull-time enrollment. The student should have only received $1388. The student was enrolled for Winter 8 and Winter for 9 hours and received Peli funds in the amount of $1850. The student should have only received $1388 Student #13: Enrolled for 10.5 hours for Summer C. The Pell funds were not disbursed prior to . the student withdrawing; however the school used the full-time Peli of 51.783 in the R2T4 7 calculation. Student #16: Enrolledfor 4.5 hours (less than )6 time) for Summer 8. The student was disbursed $1850 in Pell funds for full?time enrollment. The student should have only received 5463. Student #18: Enrolledfor 10.5 hours (3/4 time) for Winter and was paid $1850 in Pell funds for full-time enrollment. The student should have only received $1388. Student #28: Enrolled for Spring term for 18 hours from 6/13/2011 - 9/1/2011. The student signed an appeal form showing he was recalled to attend Army training in Chaffee, Arkansas from 2/15/2011 - 2/30/2011. The attendance record shows the student was required to attend 64 hours and only attended 12 hours during that time period. The form was not processed due to excessive absences.? RequiredAction: "if a student?s enrollment status changes from one term to the next, the institution must recalculate the Federal Pell Grant using the new enrollment status. If the student?s enrollment status changes within a term, the institution may have to recalculate the student?s award under certain circumstances 5 TC must conduct a ?le review of all students for the 2009/2010 and 2010/2011 award years and identify additional students who received ineligible Title l'v' Funds. Please include the results of the ?le review via diskette in an electronic spreadsheet containing the following information: - Student?s Name and Social Security Number (last 4 digits) Award Year Federal Peli Grant Disbursed Previous Enrollment Status Recalculated Federal Pell Grant Correct Enrollment Status 0 Over-A ward The institution must summarize the total amount of incorrectly disbursed Peli funds by award year. For each student in the file review, the institution must submit documentation (Account Card, Academic Transcript, and Attendance Records) STC must engage an independent Public Accountant (IPA) to test the file review completed by STC. The must develop a set of procedures designed for testing the accuracy and completeness of the ?le review. The suggested procedures must be provided to Pat Gilbert within 30 days of the institution?s receipt of this Program Review Report. Pot Gilbert will review the procedures, indicate if any changes are needed, and approve the procedures. The must apply the Agreed Upon Procedures to test the ?le review completed by STE, and prepare a report including any exceptions noted during its testing. The exceptions must be detailed and identified. Exceptions mustbe reported for all file review elements as specified in the finding requirement as presented in the Program Review Report. The lPA?s report must be submitted with response to this Program Review Report. The institution must submit the data file in a .zip file with AES (256-bitis preferred}. One way to create such a ?le is with ?WinZip 11.0, available at The department uses WinZip and the instructions for creating files with this software are enclosed. Files created with other software are also acceptable, provided they are compatible with WinZip and with AES however, the Department cannot provide support for alternate software. in addition, STC must also develop and submit with its response, procedures which will ensure that, in the future, Title i'v'funds are calculated using the correct enrollment status. The institution will be held liable for Title lV funds disbursed to studentls} without the appropriate documentation. - Repayment of liabilities will be addressed in the final program review determination letter.? Narrative Response: The College believes the Department was in error in four of the seven ?ndings, and there was no net overpayment of Pell funds in one additional ?nding, as detailed below. The College has a quarter-term programs with three modules per quarter, However, we have class starts which results in the designations for the terms (Winter, Spring, etc.) on the student?s academic transcripts not necessarin tracking neatly with the payment periods. Our ?nancial aid department is very careful to make disbursements based on payment periods that re?ect the actual enrollment status of the student-but reviewing the status of the students based on academic transcripts alone may result in an inaccurate portrayal of the student status. The information below provides data based on the actual payment periods and disbursements for the students: Student #3 w- The school agrees. Student #7 The student actually enrolled in 10.5 hours in Winter 8, not 1.5 hours. However, the school agrees that the student was not full-time. The Fall to be returned is $452.50. Student #12 ?This student took one LOA, which resulted in an over award for one quarter of $462.50. However, this was corrected and the student was under awarded $462.50 in the ?nal quarter resulting in a net over/under award of $0.00. The academic transcript for this student is being misinterpreted, which results in the appearance of the student being less than full-time twice. The student took only one leave of absence affecting his Pell disbursements. His actual attendance was as follows: ?a Quarter Months of allittendancelr Payment Hours Attempted Status Pe?od - Quarter 1 March, April, May 16.5 Full-time Quarter 2 June, July, August 15.0 Full-time Quarter 3 September, October 9.0 at time Quarter 4 January, February, March 13.5 Full-time Quarter 5 April, May, June 16.5 Full-time Quarter 6 July, August September 15.0 Full-time Quarter 7 October, November 12.0 Fullitime The school agrees that the student was over awarded Peli by $462 in Quarter 3. However, we corrected this in the ?nal payment period, resulting in no net over award. Student #13 ?This student did not receive any Pell disbursement for the payment period in question. in the student's ?nal quarter, which is the one discussed in the program review report, the student dropped before receiving aid and no Fell funds were disbursed resulting in no over award. Student #16 "This student was enrolled full-time during all periods during which funds were disbursed. His attendance and disbursements were as follows: Quarter Manths of AttendancefPayment Hours Attempted Status Fell Disbursed Pe?od Quarter 1 January, February, March 13.0 Full-time 1850 April 0.0 Drop 0.0 Quarter 2 May, June, July 15.0 Full-time 1850 Quarter 3 August, September, October 13.5 - Full-time 1850 Quarter 4 November, December, January 13.5 Full-time 1850 Quarter 5 . February, March, April (scheduled) 15.0 Full-time 1850 There is no refund due. Student #18 The student has enrolled full-time since beginning classes. As mentioned above, the fact that we have class starts can cause confusion when looking at academic transcripts. The three courses for Winter appear on the transcript as two courses in Winter and one course in Spring. However, the monthsiof attendance are March, April, and May showing consecutive attendance for that quarter. The student?s full attendance-is as follows: Quarter Months of Attendance/Payment Hours Attempted Status Pell Disbursed Pe?od Quarter 1 September, October, November 18.0 Full-time 1850 Quarter 2 December, ianuary, February 16.0 Fuli-time 1850 Quarter 3 . March, April, May 15.0 Full-time 1850 Quarter 4 June, July, August 12.0 Full-time 1850 Quarter 5 September, October, November 15.0 Full'time 1850 Quarter 6 December, January, February 17.0 Fulistime 1850 There is no over award. Student #28 This student enrolled full-time (18 hours) during Spring and began attendance in each module, There was no issue of enrollment status in this case; rather, the issue is our attendance policy. Ordinarily, the College would excuse the days missed for military service. In this case, however, the student had previously missed suf?cient unexcused days to make excusing the training days irrelevant. The fact that he missed some days of class in one course and ultimately failed that course does not alter the number of credits he actually attempted. There is no refund due. The IPA found a'0.28% overpayment error rate for 2009110 and an underpayment error rate of. 0.13% for 2010/11, resulting inan overpayment of Pell funds for 2009/10 of $14,104 and an underpayment of $8,901 for 2010111. Due to the extensive nature of the {additional research involved, and the time consuming efforts to comply with the "Required Action? of this ?nding, the response will be provided as requested in digital ?le format a copy of which will accompany this program review reSponse as required. Finding #6 Return to Title Iv R2T4'Calculation Errors Citation: "For students who withdraw from semester, trimester, or quarter programs, a school must perform the R2T4 calculation on a payment period basis. 34 C. F. R. 668.22el5} Also, the institutional charges used lathe calculation generally have to re?ect the charges for the payment period. Generally, the higher the institutional charges, the greater the amount of unearned aid that is to be returned by the school. An institution must prarate the chorgesfor the period of enrollment to correspond to a payment period. 34 C. F. R. Noncompliance: he R2T4 worksheets show the institution is checking payment period at the - top of the form versus period of enrollment. However, the dates used in Step 2 "Percentage of Title IV Earned? actually use the period of enrollment. Student The student completed a Leave of Absence form on 9/28/2009 with no reason provided for the LOA. A student status form was completed on 10/23/2009 stating the student withdrew. Funds were returned to leader on November 1, 2009 but the reviewer could not ?nd a R2T4 calculation in the file. The student was also overpaid Pell funds a discussed in Finding Student The attendance records show the Last Date of Attendance (LDA) was 2/4/2010. The R2T4 was calculated using 2/12/2010 as the withdrawal date. .Student #13: The RZT4 calculation used the 10.4 as 11/3/2009. The attendance records show the student LDA was 9/3/2009. The calculation was performed only using the funds disbursed for the payment period and the percentage was based on the period of enrollment. Required Action: ?The- use of payment period or period of enrollment is important for many aspects of the R214 calculation. To determine the treatment of Title IV funds on payment period basis, the student?s Title l'v' program assistance to be used in the calculation is the aid that is disbursed or that could have been disbursed for the payment period. Also, institutional charges used in the calculation will only reflect charges for the payment period. STC must ensure that it is using the correct elements in R2T4 calculations as stated above. The R2T4 calculation must be performed for the students listed. above. Narrative Response: Student The College has performed a new R2T4 calculation, as required (see attached original and new R2T4 calculations}. The variance between the original calculation and the current calculation is $390.54. This additional amount has been refunded to the Fall program, as reflected on the student?s ledger card. Student The College has performed a new R2T4 calculation, as required (see attached original and new R2T4 calculations]. The variance .between the original calculation and the current calculation is $125.49. This additional amount has been refunded to the Pell program, as re?ected on the student?s ledger ca rd. Student #13: The College has performed a new R2T4 calculation, as required (see attached original and new R2T4 calculations}- The variance between the original calculation and the current calculation is $1027.81. This additional amount has been refunded to the Pell program, as re?ected on the student? 5 ledger ca rd. - For Finding the College performed a review and revised R2T4 calculations for the three (3) students in question. The review indicated that the College accumtely identi?ed and used the correct beginning and and dates for each student. However, the College also found that the length of the payment period was off in each case. The re-calculations for the students in the ?nding indicate that an additional total aggregate amount of $1543.84 should have been refunded. The College has Submitted the additional refund amounts to the appropriate source of funds for each student (see refund documentation, attached). The College has also adjusted its electronic R2T4 calculation sheet to accurately and automatically identify the length of the payment period used in each R2T4 calculation. Because the College has made the additional required refunds and has adjusted its' procedure to ensure use of the correct payment period length and LDA, the College respectfully requests that Finding #6 be closed. Finding #7 Ineligible Disbursement Citation: "If a registered student withdraws or is expelled prior to the first day of classes of the period of enrollment, an institution must return any disbursed Title IV funds to the respective program. 34 C.F.R. 663.21la) if an institution disburses Title liv' funds but the student does not begin attendanceyor the institution cannot document that the student ever began attendance, it must return any funds that were credited to the student?s account, as well as the amount of any payments that the student made to the school. All schools must return funds disbursed to a student who failed to begin attendance. At a school that is required to take attendance, such as STC, it would be reasonable to expect the school to return disbursed funds immediately followingthe 14-day period the school is allowed to determine that a student is not attending class. 34 C.F.R. The Secretary considers excess cash to be any amount of Title lv, HEA program funds, other than Federal Perkins Loan Program funds, which an institution does not disburse to students or parents by the end of the third business day following the date the institution received those funds from the Secretary. 34 C.F.R. 668.166? Noncompliance: ?5 TC disbursed and retained funds for student #16 who enrolled for less than time for the period of the disbursement.? Required Action: will be required to return the funds for Student #16 if documentation can?t be provided that demonstrates the student was enrolled for at least .56 time. Repayment of liabilities will be addressed in the final program review determination letter. ln addition, policies and procedures must be implemented to show how STC will prevent ineligible disbursements in the future. A copy of the procedures must be submitted with the. institutions reSponse to this finding. Narrative Respons Student #16 was an active student when the program review was conducted and was scheduled to attempt 13.5 credits during the payment period. The student was enrolled in and actively attempting 4.5 credits at the time of the program review with an additional 9.0 credits scheduled for subsequent modules within the same term. The disbursement to the student was based on the fullvtime schedule. 7 Subsequent to the program review, the student did attempt the additional 9.0 credits for which he was scheduled. Because the student was scheduled as a full-time student and attempted sufficient credits to justify that status, the disbursement of Title IV funds was accurate and appropriate. A summary of the student?s attendance during the quarter is as follows: student Constant i 55 N: 4492 Start Date: Multan Lon! spnuu Quarter Quarter of Quarterly Begin Quarter redil: redits Attendance Period Date nd Date Course Code nurse Name Earned Grade 3 5 ummer 1 lD?'l'jZDu IT 125 Alternating urrems and assist: evices 4.5 4.5 3 ummer 8 31353011 ma TRUE Advanced as idential intuit installation 4.5 4.5 3 ummer 818(2011 maroon 1T230 ervice Installation and Troubleshooting 4.5 4.5 8 id a Torn} eons 13.5 13.5 Summer was the student's third quarter of attendance and he both attempted and earned 13.5 quarter credits during that quarter, thus his status was "full-time". (Copy of student transcript is attached.) Based upon the information-and documentation provided, Southern Technical College has?no liability under this ?nding and is in compliance with the requirements of 34 C.F.R. Therefore, the College respectfully requests that Finding ti? be closed with no additional action required of the College. Finding #8 Plus Loan Denial not Obtained Citation: dependent undergraduate student?s eligibility for an additional unsubsidized Stafford loan amount is a dependent undergraduate student for whom the financial aid . administrator determines and documents in the school's file, after review of the family financial information provided by the student and consideration of the student?s debt burden, that the student?s parents likely will be precluded by exceptional circumstances denial of a PLUS loan to a parent based on adverse credit, the student?s parent receives only publics assistance or disability bene?ts, is incarcerated, or his or her whereabouts are unknown) from borrowing under Program and the student?s family is otherwise unable to provide the student's . expected family contribution. A parent?s refusal to borrow a PLUS loan does not constitute an exceptional circumstance. 34 C.F.R. ?632.201(a) Dependent students whose parents are unable to borrow PLUS loans due to adverse credit or other exceptional circumstances may receive additional unsubsidized Stafford loans for the some amount as independent undergraduate student. The institution should examine the parent?s ability to borrow a PLUS loan using an endorser who does not have an adverse credit history before certh?/ing or origination additional unsubsidized loan amounts for the dependent student. Before certifying or origination a loan for increased loan amounts, you must document the basis of the dependent student?s eligibility. The parent?s denial of a PLUS loan based on adverse credit in one year does not support the dependent?s eligibility in subsequent years.? Noncompliance: "STCfailed to obtain PLUS denial letters for the students listed in the ?nding. Required Action: Must obtain the missing parent?s denial for the students listed above. The institution 'will. be liable for all funds disbursed if documentation is not obtained. The institution must also implement procedures to prevent reoccurrence of this finding in future Program Review or Audits and provide a copy in response to this finding. Narrative Response: STC respectfully disagrees with the non?compliance'section of this Finding, because each of these students was an independent student. The status of each of the students identi?ed in the Finding is as follows: Student #5 - This student's date of birth is clearly indicated on the enrollment agreement as 11f06f 1981. At the time the student enrolled at Southern TechnicalCollege, the student was 23 years old. The student was an independent student for Title IV purposes and no PLUS denial letter was required prior to the student applying for an unsubsidized loan under the Federal Direct Loan Program. Please see the attached enrollment agreementand ISIR for the student?s - date of birth. Student #14 - This student?s date of birth is clearly indicated on the enrollment agreement as 101D9f1974. At the time the student enrolled at Southern Technical College, the student was 35 years old. The student was an independent student for Title IV purposes and no PLUS denial lettEr was required prior to the student applying for an unsubsidized loan under the Federal Directtoan Program. Please see the attached enrollment agreement and ISIR for the student's date of birth. - Student #13 This student's date of birth is clearly indicated on the enrollment agreement as 10103,!1982. At the time the student enrolled at Southern Technical College, the student was 29 years old. The student was an independent student for Title IV purposes and no PLUS denial - letter was required prior to the student applying for an unsubsidized lo'an under the Federal Direct Loan Program. Please see the attached enrollment agreement and Eli! for the student's date of birth. Based upon the information and documentation provided, Southern Technical College has no liability under this ?nding and is in compliance with the requirements of 34 C.F.R. Therefore, the College respectfully requests that Finding #3 be closed with no-additional action required of the College. Finding #9 Invalid High School Diploma Citation: ?Citation: 34 C.F.R. states a student is eligible to receive Title iv, HEA program assistance if the student has a high school diploma or its recognized equivalent.? Noncompliance: ?Two students appear to have invalid High School Diplomas." ?Student #22?s attestation stated he received a GED from Continental Academy located in Orlando, Florida in 2006. ?Student (25% attestation stated he received a High School Diploma from Colonial High School in Orlando, Florida in May 2003.? Required Action: he institution must implement procedures to ensure the validity of high school diplomas before students are admitted and disbursed Title lV funds. A capy'af the procedures must be submitted in response to this report.? Narrative Response: Southern Technical College is aware of the requirements of 34 C.F.R. and trains its employees to comply with this regulation. Speci?cally, the College has developed a list of ?Unacceptable High Schools" that identi?es institutionis whose ?graduates? do not - qualify for admission to the College. This list was ?rst established in May 2010 based on a compilation from the California Board of Vocational Nursing and Technicians Since that time, I the College has added ?unacceptable? high schools to the list when identi?ed, along with the date the institution was added. In order to implement use of the Unacceptable High School List, the College has established the following procedure: PROCEDURE: The College shall train all admissions representatives to cross-reference the institution the student names on the high school attestation form with the institutions included on the published "Unacceptable High Schools" list. Any student that claims graduation from one of the "unacceptable" high schools on the list must be refused admission to the College by the admissions representative. in addition, the Associate Dean is required to review all admissions documentation including the attestation. If a student is erroneously accepted for admission without a proper attestation, the Associate Dean is required to reverse the student's acceptance as a student atthe College. The Deans and Associate Deans are also tasked with the responsibility of identifying additional high schools to be included on the ?unacceptable? list. This occurs most frequently when an applicant indicates graduation from an unknown high school. The DeanslAssociate Deans perform internet searches to determine the origin and nature of the high school, including but not limited to review of State-sponsored institutions, review of the high school's accredited status. and, when necessary, review of materials provided by the high school. The DeanlAssociate Dean is responsible for reporting any suspect high schools to the Board of Control (BOC) for review and possible inclusion on the "unacceptable" list. Finally, regarding the speci?c students in the Finding, the following information pertains: Student #22 attests to attending and graduating from Continental Academy. Continental Academy is currently on the College?s list of unacceptable high schools. However, the student applied to the College in January 2010 and Continental Academy was not added to the Cpllege's list until December 2010. The student?s acceptance pre?dated the date on which the College determined that the Academy is not a proper high school. Students applying to the College since December 2010 who claim to be Continental Academy graduates have not been accepted for admissions. Student #25 attests to attending and graduating from Colonial High School. Colonial High School is a well?known public High School of the Orange County Public School System (OCPSS) and has been servicing citizens of_ Orlando and Orange County since it was built in the 1950's and graduated its first class in 1960. Because the College has established and? enforces a procedure to prevent unquali?ed students from gaining admitted status. the College respectfully requests that Finding #9 be closed. (Howl/MM Ratliff Unacce table Hi School Proof of Graduation A diploma from one of the below listed schools is not acceptable as evidence of ?Proof of Graduation" from high school. Keep in mind that this list is not all-inclusive. There may be other high schools for which Proof of Graduation is unacceptable. Beware of any school that offers a high school diploma for a fee, based on limited course work, life experience or an "essay." It is important that everyone is diligent in determining whether Proof of Graduation is from an acceptable high school to help maintain our standards at Southern Technical College. The following is a list of high schools for which Proof of Graduation is unacceptable. Southern Technical College does not accept diplomas from the following schools: - School Name A School Harvest American School School Academy iPinecrest} Continental Academy '5 National Christian Academy American World Wide Anchor's Aquila Wyatt Progressive High School Church Ashwood At-Home Academics Atlanta School Atlantic Southeastern Balboa School Beach'l-iigh School Belford High School Belford University Benjamin Franklin High School Bluebonnet Private School Effective Date 1/2010 0 5/1/2010 5/ 1/201 5/ 1/ 20 10 5/1/201o 5/ 1/ 2010 5/1/2010 5/ 1/ 20 10 5! 5/ 1/201 5/ 1/20 10 10 School Name Effective Date Butler Christian Academy 511/201 Christian School Bread of Life Christian California Alternative School California Teachi School a Technical University High 5/1/2010 School Capital High School (Heritage High Castillo Christian School Centennial School School Academy &Tutoring Service Christian Vocational Cleveland Christian Colorado State Colorado State School Columbia North Online School Christian Christian Center 5/1/201 Cornerstone Christian Correspondence 5/1/20 School Cornerstone Christian School (GA) ds Christian School Sill/201 Revised 8/2011 End Home Charter School Online School School aith Christian Academv High School arington University School Coast . Fields Educational School Online School Associates News Christian School Lakes Online Christian School Online West High School Careers I School Online Adams Virtual Academy LaSalle School Online Online i Lions Lincoln Online School Lone Star State Private-School Island Home GED Macedonia School Madison Falls School School Marion Williams Bible Institute Lea Center Adult Education Masters High School (TX) 1 10 51112010 s?lzm 1 51'11201 5111'2010 5f1f201 10 5f1f2010 5f 1] 2010 Nome Metro High School LCC Midwest School Midwest Institute Midwest Adult Academy ation School Nationwide School New Christian 5111'2010 New Christian New Spiritual Foundation Christian North Central School North Star Christian School 0 Oak Brook Ba School Parkview school Questar Rochville School Senford School Sierra Summit Charter School Stratford Career institute St. Old Catholic High School 5111201 St. James St. Michaels Stepping Stones High School Stone Coast Academy Sunrise Private School Sunshine School Titan - United Christian School Universal Bible Universal Christian Park ?v'encer School Online Wisconsin School Revised 8/201 1 Finding #10 Award Letter Not Updated Citation: ?An institution must provide adequate ?nancial aid counseling to eligible students who apply for Title IV assistance. Specifically, the institution must notify the student of the amount he/she can expect to receive, and how and when those funds will be disbursed 34 C. F. R. 663.16lh)? Noncompliance: Failed to properly document the awarding of the Federal Supplemental Educational Opportunity Grant on the award letters for all students in the review scrapie.? Required Action: "The institution must develop a policy with procedures to ensure that each student is counseled and noticed of the amount of Title IV aid he/she can expect to receive, and how and when that amount will he paid. A copy of this newly developed policy and procedures must he submitted to this office in response to this finding.? Narrative Response: The College agrees with this ?nding and has developed the following policy and procedure to assure future" compliance. Polig: The College will provide each student in writing with a statement concerning the types and amounts of aid which have been awarded to the student. Any change to a student's initial package requires that a revised written statement he provided to the student in a timely manner. Procedure: The FAQ is responsible for packaging each student in a complete and comprehensive manner at the time of the?nancial aid interview based on the available relevant information provided by the student. The resulting package should include all fund sources (Pell, FDL, FSEOG, student payment plan, etc.) available to the student along with the amounts for which the student quali?es and when and how those funds will be disbursed. Once the package is complete, the FAO prints an award letter from Campus Vue containing the same information, which is provided to the student. If at any future time, the student's proposed ?nancial aid package changes as a result of veri?cation, change in enrollment status, resolution of con?icting information, or any other circumstance that alters the student?s eligibility, the FAQ must re-cou'nSel the student to explain changes in the student?s package. When any change in the student?s funding package occurs, the FAO 'must generate from Campus We and provide to the student a new award letter re?ecting those changes. Because the College has develOped and implemented its new policy and procedure concerning updating and distributing the award letter, the College respectfully requests that Finding #10 be closed and no further action required of the College in this regard. Finding #11 FSEOG Minimum'Award Requirement Not Met Citation: ?An institution may award on FSEOG in an amount it determines a student needs to continue his/her studies for an academic year. However, a Federal SEOG may not be awarded for a full academic in an amount that is less than $100 or more than $4,000. For a student enrolled for less than afuli academic year, the minimum allowable Federal SEOG award may be proportionately reduced."r Noncompliance: ?The institution is awarding students FSEOG funds in amounts less than the minimum amount of 5100. Required Action: "in response to this ?nding, the institution must develop procedures to ensare that students receive FSEOG awards that are within the minimum allowable amounts. A copy of these procedures must be submitted in response to this finding. Narrative Response:. The College has developed the following FSEOG procedure that ensures that students receive FSEOG awards that are within the minimum allowable amounts: - Federal Supplemental Educational Opportunity Grants (FSEOGI The following policies shall be relied upon in the administration of Southern Technical College?s Federal Supplemental Educational Opportunity Grants (FSEOG) program: 1. The Financial Aid Director will apply annually for FSEOGfunds in the manner and at the time speci?ed by the US. Department of Education; The Financial Aid Director will notify the President that funds have been applied for and, when appropriate, that the US. Department of Education has ailocated funds to the College; 3. The Financial Aid Director in conjunction with the campus Financial Aid Of?cer and Registrar shall determine the amount of grants to be awarded to eligible students prior to the beginning of each award year. All awards will be in the same amount for each student and shall be a minimum of $100.00 per recipient; - 4. The ?rst selection group will be those students determined through the needs analysis process to have a zero expected family contribution (000 who are receiving Pell Grants and who were enrolled in degree programs offered by the College on or after July 1 of each yea r; 5. in the event that there is an insuf?cient number of students in the ?rst selection group to account?for all available FSEOG funds, the Director of Financial Aid, in consultation with the Registrar and the campus Financial Aid Of?cer, may either increase the amount awarded to all recipients of grants during the award year in equal amounts or determine a second selection group with higher eligibility EFC to increase the number of recipients for the award year. Any changes to the grant amount or eligibility EFC that occur during the award year must be in writing and approved by the Sr. Vice President; 6. Grants shall be awarded to otherwise eligible students on a "?rst come-?rst served"r basis starting at the beginning of each award period and lasting until all available funds have been awarded; 7. The Financial Aid Director shall notify the College?s third-party ?nancial aid servicer of the names of students who have been awarded grants and the-amount of each grant; 8. The third-party servicer will schedule and disburse funds to coincide with disbursement of PELL grant funds; 9. The Registrar, Financial Aid Of?cer, and Business manager shall receive, process and post FSEOG funds in a manner identical to receiving, processing, and posting PELL grant funds; I 10. The third-partyr servicer will provide reports re?ecting FSEOG funds awarded and available; 11. The Financial Aid Director shall maintain a master list student names andamounts awarded and shall reconcile this list to the third-party servicer?s list; and 12. The Financial Aid Director shall provide the Sr. Vice President a copy of the reconciled master list during the ?rst week of each start period. Because the College has developed and implemented its new policy and procedure concerning making at least the minimum award of funds, the College requests that Finding #11 be closed and no further action required of the College in this regard. Finding #12 Credit Balance Authorization Needs Revision Citation: "in obtaining the students or parent?s authorization to perform an activity described in paragraph (will) of this section, an institution may not require or coerce the student or parent to provide that authorization, must ailow the student or parent to cancel or modify that authorization at any time and must clearly explain how it wiil carry out that activity. 34 CFR ?668.164(e) lf current year Title iv funds credited to the student?s account exceed and the totai amount of current year tuition, fees, and other authorized charges, the institution must pay the resuiting credit balance directly to the student or parent as soon as possible, but not later than 14 days after the credit balance occurred if it occurred after the first day of classes. if the credit balance occurred on or before the ?rst day of class, it must be returned no later than 14 days after the first day of class. An institution may secure a student?s written permission to retain credit balance funds for budgeting purposes, but it must be optional. The student must not be coerced into providing the school permission to retain funds'and the student must be informed of his or her right to rescind the authorization at any time. if the institution holds excess student funds, it must - 0 Identify the amount of funds it holds for each student or parentin a subsidiary ledger account designed for that purpose; - A 0 Maintain, at all times, cash in its bank account in an amount at least equal to the amount of funds the institution holds for the student; and 0 Notwithstanding any authorization obtained by the institution, pay any remaining balance on ioan funds by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which they were awarded. If a school has lost contact with a student who is due a credit balance, it must use ali reasonable means to locate him or her. if it still cannot ?nd the student, the school must return the credit balance to the lender to reduce the borrower?s loan balance, or, to. the appropriate Title iv programisj.? Noncompliance: procedure for obtaining a student?s authorization to retain Title nr credit balance funds does not appear to be optional for students. Students are required to sign a form called "Voluntary Authorization Agreement? which states ?1 authorize Southern Technical Coilege to initiate credit entries for financial aid amounts, debit entries and any adjustment to my account.? a credit balance appears on my account, authorize the institution to determine if the credit is in excess of my tuition, fees and any other applicable charges for the completion of the current ioan period or award year as applicable. if this is the case and there is a true excess, I authorize the school to hold these funds until such time as have earned the aid based on the Federal Return to Title iv Funds Policy.? The only preference the student can select is ?i authorize. the school to refund any credit balance to my lender in order to reduce my overall student loan debt. Required Action: "We also remind the institution that Title IV aid credited to a student?s account may be used to satisfy current year charges {per 34 .CFR if a student?s aid package includes a Title IV loan, the year is the loan period. lf the student does not have a loan, the year is the award year. The maximum amount of prior year charges that may be paid with current year funds is $200. STC is required to revise its procedures for the payment of and authorization to retain student credit balance funds. The student must be given the option of having their credit balances returned to them within 14 days as stated in the regulations. Returning loan funds on behalf of the student is not part of the cost of attendance. Further, the student must not be coerced into signing the credit balance authorization form as stated in the institution?s policy as a required document. The policy must be in compliance with the above. requirements and it must take effect immediately. Please provide a copy of your revised policy and authorization form in response to this finding. Narrative Response: in response to this ?nding, the College has revised its policy on authorizations and holding credit balances. The new policy is as follows: Polig: When Title IV funds awarded to a student result in a credit balance in the student's account, the College will disburse funds in the amount of the credit balance to the student via written check. The disbursement will occur within 14 days of either the ?rst day of classes in the disbursement period or the date the Title IV funds are received by the College, whichever is later. The College has ceased holding credit balances and follows the 14*day rule with all credit balances'that resulted from the awarding of FSA funds. Since the College has ceased to hold credit balance funds, the College has removed the Voluntary Authorization form from the packet of ?nancial aid interview materials and there is no expectation that students will sign such a form in the future. .Because the College has re?written its policy concerning handling excess FSA funds and because the College no longer includes a Voluntary Authorization form that students are expected to sign, the College respectfully requests that Finding #12 be closed with no further action required on the part of the College. Finding #13? Policy and Procedures Manual Missing Citation: "To participate in the Federal Student Aid programs, a school must demonstrate that it is administratively capable of providing the education it promises and properly managing the FSA programs. 34 CFR 668.15? Noncompliance:. does not currently have a policies and procedures manual that describes how all the various functions described in 34 CFR 668.16 are being properly administered.? Required Action: ?While the regulations do not specifically state that an institution must have a policies and procedures manual, it does however state that an institution must demonstrate that it is capable of adequately administering the program under each of the standards established in this section. The Financial Aid Director stated the manual was still in the developing stages. in response to this 7 ?nding, STC must provide 'a copy of the manual.? Narrative Response:_A copy of the College's policies and procedures manual is attached. Having complied with the required action for this ?nding, the College respectfully requests that the ?nding be closed with no additional action required. SALMON SIMS THOMAS Accountant: and Consultant: June 5, 2012' U.S. Department of Education, Case Management Atlanta, Georgia . RE: Soother-n Technical College 03903500 In The follow-up to the Program Review 201140427638, for the award years 200912010 and 201012011, we tested 234 out of the sample population of 596 of Southern Technical College?s student ?les documentation in response to. Finding 1 Con?icting Information and Finding 2 Pell UnderpaymentSIOvei-payments for a 95% con?dence level with a 5% margin of error. Our examination was made in accordance with Government Auditing Standards,- issued by the Comptroller General of the United States; attestation standards established by the American Institute of Certi?ed Public Accountants; and the Audit (Attestation) Guide. Auditsfattestation Engagements of Federal Student Financial Assistance Programs, issued by the US. Department of Education, Of?ce of the Inspector General, as updated. Finding No. - Con?icting Information In'the 200912010 and 2010/2011 award years the Institution had information in the student ?le that con?icted with that ?om the ISIR. This resulted in a 34% error rate, within'the sample, in the 200912010 award year and a 1.61% in the 201012011 award year. When applied to the entire population it resulted in a liability of $5,167 in 200912010 and $27,340 in 201032011 to the Federal Pell Grant Program. Finding No. 2 Pelt In the 200951010 and 2010/2011 the Institution made overpayments and underpayments to the Federal Pell Grant Program. This resulted in a 28% overpayment error rate, within the sample, in- the 2009/2010 award year and a .13% under-payments error rate in the 201012011 award year. When applied to the entire population it resulted in a liability of $14,104 in 200912010 and ($8,901) in 201012011 to the Federal Pell Grant Program. ?focused your .1 - - US. Department of Education, Case Management Atlanta, Georgia Page Two In our opinion, Southern Technical Institute has complied with the requirements of the above menticmed ?ndings. We werenot engaged to, and did not conduct an audit, the objective of which would be the expression of an opinion, on the accounting record. Accordingly, we do not express such an. opinion. Had we perfonned additional procedures, other mattersrnight have come to our attention that would have been reported to you. This report is intended solely for the information and use of Southern Technical Institute and Department of Education, and is not intended to be and should not be used by anyone other than those speci?ed parties. . Luz-u..- "tahnon, Sires Thomas Associates,'PPLC,. I Final Program Review Determination PRCN 201140427638 Appendix 0 Program Review Report 1mm March is, 2012 Mr. John Euliano, President Southern Technical College . UPS 1485 Florida Mall Avenue Tracking 67Y 01 9126 1827 Orlando, FL 32809?0000 RE: . Program Review Report OPE ID: 03903500 PRCN: 201140427638 - Dear Mr. Euliano: From August 29, 2011 through September 2, 2011, Pat Gilbert, Sherry Blackman and Angelique James as representatives of the US. Department of Education conducted a review of Southern Technical" College?s (STC) administration of the programs authorized pursuant to Title IV of the Higher Education Act of 1965, as amended, 20 USS. 1070 et seq. (Title IV, HEA The ?ndings of that review are presented inthe enclosed report. Findings of noncompliance are referenced to the applicable statutes and regulations and specify the action required to comply with the statute and regulations. Please review the report and respond to each ?nding, indicating the corrective actions taken by STC. The response should include a brief, written narrative fer each ?nding that clearly states position regarding the ?nding and the corrective action taken to resolve the ?nding- Separate from the written narrative, STC must provide supporting documentation as required in each ?nding. Please note that pursuant to section 498A(b), the Department is required to: (1) provide to the institution an adequate opportunity to review and respond to any preliminary to am review re It] and relevant materials related to the re on before an i gr .130 ?nal program review report is issued; (2) review and take into consideration an institution?s response in any ?nal program review report or audit determination, and include in the report ordeterrnination a. . A written statement addressing the institution?s re5ponse; b. A written statement of the basis for such report or determination; and c, A copy of the institution?s response. 1 A ?preliminary? program review report is the program review report. The Department?s ?nal program review report is the Final Program Review Determination (FPRD). Federal Student Aid, School Participation Team - Atlanta 6] Street, S.W., Room 18T40, Atlanta, GA 30303-3104 FEDERAL STUDENT AID HERE. GO EURTH ER. . Southern Technical College OPE 20] 140427638 Page 2 of 2 The Department considers the institution?s response to be the written narrative (to include e?mail communication). Any supporting documentation submitted with the institution?s written response will not be attached to the FPRD. However, it will be retained and available for inspection by STC upon request. Copies of the program review report, the institution?s response, and, any supporting documentation may be-subject to release under the Freedom of Infonnation Act (F 01A) and can be provided to other oversight entities-after the FPRD is issued. The institution?s response should be sent directly to Pat Gilbert of this of?ce within 60 calendar days of receipt 'of this letter. Record Retention: - Program records relating to the period covered by the program review must be retained until the later of: resolution of the loans, claims or expenditures questioned in the program review; or the. end of the retention period otherwise applicable to the record under 34 C.F.R. We would like to. express our appreciation for the courtesy and cooperation extended during the review. Please refer to the above Program Review Control Number (PRCN) in all correspondence relating to this report?. If you have any questions concerning this report,.please contact Pat Gilbert at (404) 974?9292 or - Sincerely, . Chris Miller Team Leader cc: Mr. Richard Bennett, Financial Aid Administrator Enclosure: Protection of Personally Identi?able Information PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION Personally Identi?able information (Pll) being submitted to the Department must be protected. PM is any infon'nation about an individual which can be used to distinguish or trace an individuat?s identity (some examples are name, social - security number, date and piece of birth). - being submitted electronically or on media CD-ROM, ?oppy disk, DVD) must'be The data must be submitted in a .zip ?le with Advanced Standard (AES) (256-bit is preferred). The - Department uses WinZip. However, ?les created with other software are also, acceptable, provided that they are compatible with.WinZip (Version 9.0) and are with AES Zipped?les uSing WinZip must be saved as Legacy compression {Zip 2.0 compatible). The Departrnent must receive an access password to view the information. The password must be e-mailed separately from the data. The password must be 12 characters in length and use three of the following: upper case letter, lowercase letter, number, special character. A manifest must be_ included with the entail that lists the types of ?les being sent (a copy of the manifest-must be retained by the sender). Hard copy ?les and media containing must be: - sent via a shipping method that can be tracked with signature required Upon delivery - double packaged in packaging that is approved by the shipping agent A . (FedEx, DHL, UPS, USPS) - labeled with both the "To" and "From" addresses on both the-inner and outer packages - - identi?ed by a manifest included in the inner package that lists the types of ?les in the shipment (a copy of the manifest must be retained by the sender). - . data cannot be sent via fax. A START ill! - 3.2.1 30 Prepared for STUDENT Southern Technical College OPE 03903500 201 14042 7638 Prepared by U.S. Department of Education Federal Student Aid School Participation Team Atlanta Program Review Report March 15, 2012 61 Street, S.W., Room 13T40, Atlanta, GA 30303?3 104 Southern Technical College 201140427633 Page I of 21 Table of Contents Institutional ., .. Scope of Review .. Findings l. Con?icting Information 2. Incomplete Veri?cation 3. Dependency Override Not Properly Documented Academy Policy Stricter than Satisfactory Academic Policy (SAP) 5. Pell UnderpaymenUOverpayment 6. Return to Title IV 9R2T4) Calculation Eners 7- Ineligible Disbursement - . . 8. Plus Loan Denial not Obtained 9. Invalid High School Diploma 10. Award Letter Not Updated 11. SEOG Minimum Award Requirement Not Met 12. Credit Balance Authorization Needs Revision 13. Policy and Procedures Manual Missing Appendix A Student Sample AppendiX'B 200912010 Statistical Sample Appendix 2010:9010 Statistical Sample Page .14 15 16 16 16 18 Southern Technical College OPE 03903500 201 14042763 8 Page 2 of 2] A. Institutional Information Southern Technical college 1485 Florida Mall Avenue Orlando, FL 32809-0000 Type: Proprietary Highest Level of Offering: Associate?s Degree Accrediting Agency: Accrediting Council for Independent Colleges and Schools Current Student Enrollment: 1134 (2010/2011) of Students Receiving Title IV: 99.38% (201012011) Title IV Participation: Grants Administrative and'Payment System (G5): . 200912010 201012011 Federal Pell Grant $5,334,008 7,180,094 - Federal Supplemental Educational Opponunity Grant (SEOG) 19,779 25,000 Academic Competitiveness Grant (ACG) 11,868 10,015 Federal Direct Loan (DL) $7,131,380 $12,264,937 Default Rate FFEUDL: 2009 13.3% . 2008 3.2% 2007 9.6% Southern Technical College 201140427638 Page 3 of 21 B. Scope of Review The US. Department of Education (the Department) conducted a program review at Southern Technical College (STC) from August 29, 2011 to September 2, 2011. The review was conducted by Pat Gilbert, Sherry Blackman and Angelique James. The focus of the review was to determine compliance with the statutes and federal regulations as they pertain to the institution's administration of Title IV programs. The review consisted of, but was not limited to, an examination of policies and procedures regarding institutional and student eligibility, individual student ?nancial aid. and academic ?les, attendance records, student account lodgers, and ?scal-records. . A sample of 30 ?les was identi?ed for review from the 200912010 and 20101201 1"(year to date) award years. The ?les were selected randomly from a statistical sample of the total population receiving Title IV, program funds for each award year. Appendix A lists the names and partial social security numbers of the students whose ?les were eXamined during the program review. Disclaimer: Although the review was thorough, it cannot be assumed to be all-inclusive. The absence of statements in the report concerning STC?s'speci?c practices and procedures must not be construed as acceptance, approval, or endorsement of those speci?c practices and - - procedures. Furthermore, it doesnot relieve STC of its obligation to comply'with all of the statutory or regulatory provisions governing the Title IV, HEA programs. This report re?ects initial ?ndings. These ?ndings are not ?nal. The Department will issue its ?nal ?ndings in a subsequent Final Program Review Determination letter- C. Findings During the review, several areas of noncompliance were noted. Findings of noncompliance are referenced to the applicable statutes and regulations and specify the actions to be taken by STC to bring Operations of the ?nancial aid programs into compliance with the statutes and regulations. Southern Technical College L7 201140427638 Page 4 of 21 I Finding Con?icting Information Citation: The ability of an institution to coordinate the information it collects and to resolve discrepancies are critical elements in an evaluation of its administrative capability. Regulations require institutions to develop an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student?s application for ?nancial aid under Title IV, programs. 34 and - Noncompliance: STC failed to resolve the discrepant information for the below students: Student The FAFSA signed on 11/6/2009 shows the student as single. Leave of Absence (LOA) paperwork dated 45/2010 and 1119219010 shows the student reason for the LOA as ?separation?- with Spousef Student #16: The student was not selected for'verification; however the student had a' ?C?-code that needed to be resolved and the institution should have resolved all the discrepant information. The enrollment application shows the student as married. The student reported single on the FAFSA and reported only his income. The Household size was reported as 3. Student #22: The student was not selected for veri?cation. However, the student has a code that needed to be resolved and the Institution should have resolved all the discrepant information. I Enrollment Agreement and Veri?cation Worksheet show ?married? and'the FAFSA reported.?single?. - Incorrect status of ?Head of HOusehold? used on Tax can 104 I code for Selective Service was not resolved Student #25: The student was not selected for veri?cation for the '20] (#201 1 award year but was selected for the 200999010 award year. The enrollment agreement shows the student as a single male and the-student answered to the question on enrollment agreement regarding are you a single parent. The student FAF SA reported 2 in house- hold size and on the veri?cation worksheet for 20092010. ,The student also ?led an amended tax return for 2008 changing the ?ling status as ?single? rather than ?head of household?. - Student #28: The studentwas not selected for veri?cation. However, the enrollment agreement shows the student as a single male and not a single parent. The FAF SA shows 2 in household size and the student answered ?yes? to the question regarding children you support- Southern Technical College 20] 140427638 Page 5 of 21 Required Actiom The program review was conducted due to several complaints from male students that they were being directed by of?cials at STC to report dependents when in fact they were not providing over 50% support. The discrepant information for the students identi?ed above reveals questionable information reported on the PAP SA and the Enrollment Agreement. In response to this ?nding, STC must resolve the discrepant information for the students listed above and provide supporting documentation. STC must also conduct a ?le review of all the students for the 2009112010 and 201012011 award years to determine if corrections to the household size would result infa change to the Estimated Family Contribution (EFC) where there is conflicting information regarding household-size and answers givenby students on either the FAFSA or Institution?s enrollment agreement. 7 Please include the results of the file review via diskette or in anelectronic spreadsheet, containing the following information: Student?s Name and Social Security Number (last 4 digits only) Revised Title aid Entitlement Ineligible award amounts and refunds due to the Title 1V programs 1. 2. Award Year 3-.- Original EFC 4. Title IV aid disbursed 5. Revised EFC 6. 7. In lieu of performing a ?le review for the entire population {1504) for 200912010 and (1830) for the 2010/2011 award year to determine actual iiabilities, STC has the option of . performing this ?le review for only the remainder of the statistical sample not tested by the Department during the program review (308 for 200912010 and 320 for 201012010 remaining in the statistical samples). The results from this ?le review using the statistical Sample will be used to project liabilities for the entire population the average - liability for the recipients in the statistical sample will be multiplied by the total population). This option is intended to reduce the burden on the institution of conducting a full ?le review. If STC wishes to select this option, please use the attached statistical sample listings for award years 2009/2010'and 2010/2011 (Appendix and C) for this ?nding. File reviews must be performed for all students on each statistical sample listing except those included in Appendix A of this Program Review Report for the reSpective award year. Southern Technical College 'I?D'ii 03903500 20] 140427638 Page 6 of 2] If STC elects to do the full ?le review; it is recommended that STC ?rst review the remainder of the students in the statistical sample. At that point, STC may decide to accept liability projection instead of continuing with a ?le review. STC must engage an Independent Public Accountant (EPA) to test the ?le review completed by STC. The IPA must deve10p a set of procedures designed for testing the accuracy and completeness of the ?le review. The suggested procedures must be provided to Pat Gilbert within 30 days of the institution?s receipt of this Program Review - Report. Pat Gilbert will review the procedures, indicate if any changes are needed, and approve the procedures. 7 The IPA must apply the Agreed Upon Procedures to test the ?le review completed by STC, and prepare a report including any exceptions noted during its testing. The exceptions must be detailed and identi?ed. Exceptions must be reported for all ?le review elements as speci?ed in the ?nding requirement as presented in the Program Review Report. The report must be submitted with response to this Program Review Report. Payment instructions for any determined liability will be provided in the inal Program Review Determination Letter. Finding Incomplete Veri?cation Citation: If the Central Processing System (CPS) selects an application for veri?cation, an institution must verify ?ve major data elements (household size, number enrolled in coliege, adjusted gross income (AGI), US. income tax paid, and certain untaxed income and bene?ts). An institution can verify AGI and U.S. income tax paid by getting a copy of the signed US. income tax return. If a copy of the tax return is not available, the student must instead submit a copy of any IRS form that lists tax information and provides the information needed for veri?cation. The form mtg, be signed-by the student unless the IRS sent the from directly to the school. 34 C.F.R. 668.56, 668.57 Noncompliance: Student #10 was selected for veri?cation f0r the 2008:0009 award year. The FAFSA shows the student as married. The student?s ?ling status on the 2003 tax return shows ?head of household?, this is an incorrect ?ling'status. The student was disbursed Pell funds in the amount of $3154, subsidized loans of-$3500 and unsubsidized loans of $5850. For the 200912010 award year, the student was not selected for veri?cation. However, the tax return only shows 3 exemptions but the household size is 6 on the The student was disbursed Pell ?mds in the amount of $5350, subsidized loans of $4500 and unsubsidized loans of $6000. Southern Technical College OPE 201140427638 Page 7 of 21 Required Action: STC must obtain the proper IRS tax forms to complete the veri?cation process. Failure to obtain the correct tax documents will result in a liability for the funds disbursed- Finding Dependency Override Not Properly Documented Citation: The Higher Education Act allows an aid administrator to make dependency overrides on a case-by-case basis for students with unusual circumstances. If the administrator judges that an override is appropriate, hefshe must document the unusual circumstances. However, none of the conditions listed below, singly or in conjunction, qualify as unusual circumstances or merit a dependency override: HEA Sec. 480(d)(7) Parents refuse-to contribute to the student?s education Parents are unwilling to provide information on the application or for veri?cation; Parents do not claim the student as dependent for income tax purposes; Student demonstrates total self-suf?ciency. If the ?nancial aid administrators use professional judgment, the adjustment must'be based on a student?s individual circumstances and" must be documented in the student?s ?le. The documentation supporting the oven'ide must be adequate. There should be supplementaryinformation supporting the ?nding of an unusual circumstance necessitating the dependency override. The school is held accountable for all professional judgments make and each decision must be fully documented. So, although the Department Will not second-guess the Financial Aid Administrator, there is a baseline of reasonableness that any professional judgment adjustment should meet, as well as, the requirement that the reason be adequately documented. Noncompliance: STC used Professional Judgment to make student #19 (20 years old) an Independent student based on the statement that he provided more than 50% of his girlfriend?s (20 years old) support for the year with only $3,908 in income. Dependency Override can?t be used to waive general student eligibility requirements orto circumvent I the'intent of the law or regulations. Required Action: The Institution must provide a statement from the girlfn'end regarding the amount of income she receives and the amount of support provided by the student on her behalf. 7 . Payment instructions for any determined liability will be provided in the Final Program Review Determination Letter. Southern Technical College '7 20] 140427633 Page 3 of 21 Finding-#4: Academic Policy Stricter than Satisfactory Academic Policy Citation: For purposes of determining student eligibility for assistance under a Title IV, HEA program, establishes, publishes, and applies reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory progress in hisfher educational program. The Secretary considers an institution?s standards to be reasonable if the standards are the same as or stricter than the institution?s standards for a student enrolled in the same educational program who is not receiving assistant under a? Title IV, HEA program. 34 can. 668.16(e) - Noncompiiance: STC academic policy is stricter than the Satisfactory Academic Policy (SAP) for students receiving Title IV funding. A Academic Policy Any student whose GPA falls below 2.0 m_ay be placed on academic warning. However, students may not be subject to further action unless their academic achievement or credit completion rate falls below the satisfactory progress parameters outlined below. Student may also be placed on an academic warning if their class attendance falls below 60% for a given course, and all students seeking re-enrollment as a regular student follOwing a suspension for academic progress will be placed on academic warning. A student on academic warning my be counseled and given assistance, if needed, to improve his/her GPA. SAP Policy - A student must meetthe following minimum standards of academic - achievement and successful course completion while enrolled-at STC. 7 . Degree Student's I Diploma Students Credits Attempted Minimum GPA Credits Attempted Minimum GPA 0?233 - 1.00 0~23 1.00 24 4 47.9 1.25 24 - 42.0 1.50 48 - 71.9 1.50 43 and Up 2.00 72 39.9 1.75 90 and 'Up 2.00 The following discrepancies were identified in relation to SAP testing. Student The student?s GPA for the end of Spring was 1.00. The student . reenrolled for. Summer and the term GPA was 1.20 with a cumulative GPA of 1.56.' Fall 13 term GPA 0.25 and Cumulative GPA 1.15. The student continued enrollment for Winter and received all, F?s and cumulative GPA of 0.91. Southern Technical College -- 20] 14042763 8 Page 9 of 2] Student #16: The student was placed on Academic Warning for the Summer term with a cumulative GPA of 1.77. Student #19: The student Term GPA for Fall was 0.67. The student re-enrolled for the Winter term and received 2 F?s and a WP receiving a GPA of 0 and Cumulative GPA of 1.44. Required Action: STC must utilize the Academic Policy in place at the time of the review and conduct a ?le review for the 200912010 and 2010/2011 awards years to determine if any student should have been placed on Academic Probation or Suspension based on that policy. - - The result of the file review must be submitted in the following format: Student?s Name . Social Security Number . Student?s SAP Category (ie. full-time, part-time, etc.) Qualitative Determination at Each Measured Increment Hours Completed at Each Measured Increment Result of Correct Policy Application Amount(s) and Date(s) of Any Incorrectly Disbursed Funds, by Program In lieu of performing a ?le review for the entire population (1504) for 200912010 and (1830) for the. 20102011 award year to determine actual liabilities, STC has the option of performing this ?le review for only the remainder of the statistical sample not tested by the Department" during the?program review (308 for 2009/2010 and 320 for 201012010 remaining in the statistical samples). The resolts from this ?le review'using the statistical I sample will be used to project liabilities for the entire population the average liability for the recipients in the statistical sample will be multiplied by the total population). This option is intended to reduce the burden on the institution of conducting a full ?le review. If STC wishes to seiect this option, please use the attached statistical sample listings for award years 200912010- and 201012011 (Appendix and C) for this ?nding. File reviews must be performed for all students on each statistical sample listing except those included in Appendix A of this Program Review Report for the respective award year. - If STC elects to do the 'full ?le review; it is recommended that STC first review the remainder of the students in the statistical sample. At that point, STC may decide to accept liability projection instead of continuing with a full ?le review. If the Institution decides to revise its policy, it must prbvide a copy of that policy in response to this report and ensure that all students and staff are informed of the new Standards. Southern Technical College 201 140427633 Page 10 of21 STC must engage an Independent Public Accountant (IPA) to test the ?le review completed by STC. The IPA must develop a set of procedures designed for testing the accuracy and completeness of the ?le review. The suggested procedures must be provided to Pat Gilbert within 30 days of the institution?s receipt of this Program Review Report. Pat Gilbert will review the procedures, indicate if any changes are needed, and approve the procedures. The IPA must apply the Agreed Upon Procedures to test the ?le review completed by STC, and prepare a report including any exceptions noted during its testing. The exceptions must be detailed and identi?ed. Exceptions must be reported for all ?le review elements as speci?ed in the ?nding requirement as presented in the Program Review Report. The report must be submitted with response to this Program Review Report. 7 - Payments instructions for any determined liability will be provided in the Final Program Review Determination Letter. Finding Pell Underpayments/Overpayments Citation: If an institution uses credit hours and academic terms to measure a student?s progress, then the student?s enrollment status (?ll-time, three-quarter time, half-time or, less than half-time) is used to calculate the amount of the student?s Federal Pell Grant payment. A school may use its own standards for enrollment status, provided the standards meet the minimum requirements de?ned in regulations. 34 GER. 690. 63(6) Noncomp'liance: The students identi?ed below were overpaid due to their enrollment status: Student Enrolled for 6 hours (1/2 time) for Summer The student was disbursed Pell funds in the amount of $1784 for full time status. The student should have received $891.00. The school returned $189.52 on 1 1/112009 based on the student?s withdrawal. A Student Enrolled for 1.5 hours for Winter B. The student was disbursed $1850 in Pell funds for full-time enrollment. The student should have only received $1388. Student #12: Enrolled for 9 hours for Summer C. The student was disbursed $1850 in Pell funds for full-time enrollment. The student should have only received $1388. The student was enrolled for Winter and Winter for 9 hours and received Pell funds in-the amount of $1850. The student should have only received $1388. Southern Technical College 201 140427638 Page 11 of21 Student #13: Enrolled for 10.5 hours for Summer C. The Pell funds were not disbursed prior to the student withdrawing; however the school used the full time Pell of $1783 in the R2T4 calculation. Student #16: Enrolled for 4.5 hours (less than time) for Summer B. The student was disbursed $1850 in Pell funds for full-time enrollment. The student should have only received $463. Student #18: Enrolled for 10.5 hours'(3f4 time) for Winter and was paid $1850 in Pell funds for enrollment. The student should have only received $1388. Student #28: Enrolled for Spring term for 18 hours from 9flf2011. The student signed an appeal form showing he was recalled to attend Army training in Chaffee, Arkansas from 711512011 713019011. The attendance record shows the student was required to attend 64 hours and only attended 12 hours during that time period. The form was not processed due to excessive absences. Required Action: If a-student?s enrollment status changes from one term to the next, the institution must recalculate the Federal Pell Grant using the new enrollment status- If the student?s enrollment status changes within'a term, the institution may have to recalculate the student?s awardunder certain circumstances. - STC must conduct a ?le review of all students for the 2009/2010 and 20109011 award years and identify additional students who received ineligible Title IV funds. Please include the results of the ?le review via diskette in an electronic spreadsheet, containing the following information: Student?s Name and Social Security Number (last 4 digits) Award Year Federal Pell Grant Disbursed Previous Enrollment Status Recalculated Federal Pell Grant Correct Enrollment Status Over-award The institution must summarize the total amount of incorrectly disbursed Pell funds by award year. For each student in the ?le review, the institution must submit documentation (Account Card, Academic Transcript, and Attendance Records). STC must engage an Independent Public Accountant (IPA) to test the ?le review completed by STC. The IPA must develop a set of procedures designed for testing the accuracy and completeness of the ?le review. The suggested procedures must be Southern Technical College OPE 11313 03903500 20] 140427638 Page 12 of 21 It. provided to Pat Gilbert within 30 days of the institution?s receipt of this Program Review Report. Pat Gilbert will review the procedures, indicate if any changes are needed, and approve the procedures. - The IPA must apply the Agreed Upon Procedures to test the ?le review cempleted by STC, and prepare a report including any exceptions noted during its testing. The - exceptions must be detailed and identi?ed. Exceptions must be reported for all ?le review elements as speci?ed in the ?nding requirement as presented in the Program Review Report. The report must be submitted with response to this Program Review Report. - The institution must submit the data ?le in a .zip ?le with AES - (256-bit is preferred). One way to create such a file is with WinZip 11.0, available at The Department uses WinZip and the instructions for creating ?les with this software are enclosed. Files created with other software are also acceptable, provided they are compatible with WinZip and with AES however, the Department cannot provide support for alternate software. In addition,- STC must also develop and submit with its response, procedures which will ensure that, in the ?iture, Title IV funds are calculated using the correct enrollment status. The institution will be held liable for Title IV funds disbursed to student(s) without the appropriate documentation. - Repayment of liabilities will be addressed in the ?nal program review determination letter. Finding Return to Title Calculation Errors Citation: For students who withdraw from semester, trimester, or quarter programs, a school must perform the R2T4 calculation on a payment period basis. 34 CPR. 668.22e(5) Also, the institutional charges used in the calculation generally have to re?ect the charges. for the payment period. Generally, the higher the institutional charges, the greater the amount of unearned aid that is to be returned by the school. An institution must prorate the charges for the period of enrollment to correspond to a payment period. 34 C.F.R. 668. 22(g)(1)(ii) Southern Technical College OPE-191303903500 201140427638 Page 13 of 2] Noncompliance: The R2T4- worksheets show the institution is checking payment period at the top of the form versus period of enrollment- However, the dates used in Step 2 ?Percentage of Title IV Aid Eamed? actually used the period of enrollment. Student The student completed a Leave of Absence form on 9/28/2009 with no reason provided for the LOA. A student status form was completed on 10/23/2009 stating the student withdrew. Funds were returned to lender on November 1, 2009 but the reviewer could not ?nd a R2T4 calculation in the ?le. The student was also overpaid Pell funds as discussed in inding Student The attendance records show the Last Date of Attendance (LDA) was 2/4/2010. The R2T4 was calculated using 2/ 12/2010 as the withdrawal date. Student #13: The R2T4 calculation used the LDA as 1 1/3/2009. The attendance records show the student LDA was 9/3/2099. The calculation was performed only using the ?inds disbursed for the payment period and the percentage was based on the period of enrollment. Required Action: The use of payment period or period of enrollment is important for many aspects of the R2T4 calculation. To determine the treatment of Title IV ?mds on payment period basis, the student?s Title IV program assistance to be used in the calculation is the aid that is disbursed or that could have been disbursed for the payment period. Also, institutional charges used in the calculation will only re?ect charges for the - payment period. STC must ensure that it is using the correct elements in R2T4 calculations as stated above. The R2T4 calculation must be performed the students listed above. Finding Ineligible Disbursement Citation: If a registered student withdraws or is expelled prior to the ?rst day of classes of the period of enrollment, an institution must return any disbursed Title IV funds to the respective program. 34 C.F.R. 668.21(a) If an institution disburses Title IV funds but'the student does not begin attendance or the institution cannot document that the student ever began attendance, it must return any funds that were credited to the student's account, as well as the amount of any payments that the student made to the school. All schools must return funds disbursed toa student who failed to begin attendance. At a school that is required to take attendance, soch as STC, it would be reasonable to expect the school to return disbursed ?Jnds immediately Southern Technical College 7 . 201140427638 - Page 14 of21 following the 14-day period the school is allowed to determine that a student is not attending class. 34' CFR The Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan Program funds, which an institution does not disburse to students or parents by the end of the third business day following the date the institution, received those ?inds from the Secretary. 34 C.-F.R. 668.166 - . Noncompiiauce: STC disbursed and retained funds for student #16 who enrolled for less than V2 time for the period of the disbursement. . Student #16: Enrolled for 4.5I?hours (less than 1/2 time) for Summer term. The student was disbursed $1161 Subsidized and $1990 Unsubsidized loans. Required Action: STC will be required to return the funds for Student #16 if documentation can?t be provided that demonstrates the student was enrolled for at least time. Repayment of liabilities will be addressed in the ?nal program review determination letter. - In addition, policies and procedures must be implemented to show how STC will prevent ineligible disbursements in the future. A copy of the procedures must be submitted with the institution?s response to this ?nding. . Finding Plus Loan Denial not Obtained Citation: A dependent undergraduate student?s eligibility for an additional unsubsidized Stafford loan amount is a dependent undergraduate student for whom the ?nancial aid administrator determines and documents in the school?s ?le, after review of the family ?nancial information provided by the student and consideration of the student?s debt burden, that the student?s parents likely will be precluded by eXceptional circumstances denial of a PLUS loan to a parent based on adverse credit, the student?s parent receives only publics assistance or disability bene?ts, is incarcerated, or his or her - whereabouts are unknown) from borrowing under the PLUS Program and the student?s family is otherwise unable to provide the student?s expected family contributions A parent?s refusal to borrow a PLUS loan does not constitute an exceptional circumstance. 34 can. 682201611) OPE 03903500 201140427638 Page 15 of 2] Dependent students whose parents are unable to borrow PLUS loans due to adverse credit or other exceptional circumstances may receive additional unsubsidized Stafford loans for the same amount as independent undergraduate student. The Institution should examine the parent?s ability to borrow a PLUS loan using an endorser who does not have an adverse credit history before certifying or originating additional unsubsidized loan amounts for the dependent student. Before certifying or originating a loan for increased loan amounts, you must document the basis of the dependent student?seligibility. The . parent?s denial of a PLUS loan based on adverse credit in one year does not support the dependent?s eligibility in subsequent years. Noncompliauce: STC failed to obtain PLUS denial letters for the students listed below: Student Received additional Unsubsidized loan for the following loan periods: 7/2/2007 113112003 ($2245); 2.1412008 8128/2008 ($2470). The Institution must obtain PLUS denial for each loan period. I . Student #14: The student was awarded a $4000 FFEL Unsubsidized loan for loan period - 2/4/2008 83812008. No PLUS denial letter was in the - . Student #18: The student was awarded a $2,150 FF EL Unsubsidized loan, for loan period 2fl6f2009 8f20f2009. No PLUS denial letter was in the ?le. Required Action: STC must obtain the missing parent?s denial for the students listed above. The Institution will be liable for all funds disbursed if documentation is not obtained. The Institution must also implement procedures to prevent reoccurrence of this ?nding in future Program Review or Auditsand provide a copy in response to this ?nding. Finding Invalid High School Diploma Citation: Citation: 34 C.F.R. states a student is eligible to receive Title IV, HEA program assistance if the student has a high school diploma or its recognized equivalent. - Noncompliance: Two students appear to have invalid High School Diplomas. Student #22?5 attestation stated he received a GED from Continental Academy located in Orlando, Florida in 2006- Southern Technical College, 03903500 201140427633 - Page 16 of 21 Student #25?5 attestation stated he received a High School Diploma from Colonial High School in Orlando, Florida in May 2003. Required Action: The Institution must implement procedures to ensure the validity of high school diplomas before student are admitted and disbursed Title IV hands. A copy of the procedures must be Submitted in response to this report. These appear to be isolated incidents. Finding #10: Award Letter Not Updated Citation: An institution must provide adequate ?nancial aid counseling to eligible students who apply for Title IV assistance. Speci?cally, the institution must notify the student of the amount he/she can expect to receive, and how and when those funds will be will be disbursed. 34 C.F.R. Noncompliance: STCfailed to properly document the awarding of the Federal Supplemental Educational Opportunity Grant (FSEOG) on the award letters for all students in the review sample. Required Action: The Institution must develop a policy with procedures to ensure that each student is counseled and noti?ed of the amount of Title IV aid he/she can expect to receive, and how and when that amount will be paid. A copy of this newly developed policy and procedures must be submitted to this of?ce in responSe to this ?nding. _Finding_#ll: FSEOG Minimum Award Requirement Not Met Citation: An institution may award an FSEOG in an amount it determines a student needs to continue hisfher studies for an academic year. However, a Federal SEOG may not be awarded for a full academic in an amount that is less than $100 or more than 34,000: For a student enrolled for less than a full academic year, the minimum allowable Federal SEOG award may be proportionately reduced. Noncompliance: The Institution is awarding students FSEOG ?mds in amounts less than the minimum amount of $100. Required Action: In response to this ?nding, the institution must develop procedures to ensure that students receive FSEOG awards that are within the minimum allowable amounts. A copy of these procedures must be submitted in response to this ?nding. Southern Technicalmgollege I OPE 03903500 201 1404237638 Page 17 of 2] Finding #12: Credit Balance Authorization Form Needs Revisions Citation: In obtaining the student?s or parent?s authorization to perform an activity described in paragraph (1) of this section, an institution may not require or coerce the student or parent to provide that authorization, must allow the student or parent to cancel or modify that authorization at any time and must clearly explain how it will carry out that activity. 34 C.F.R. 668.I64(e) If current year Title IV funds credited to a student's account exceed the amount of current - year tuition, fees, and other authorized charges, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but no later'than 14 days after the credit balance occurred if it occurred a?er the ?rst day of class. If the credit balance occurred on or before the ?rst day of class, it must be returned no later than 14 days after the ?rst day of class. An institution may secure a student's written permission to retain credit balance funds for budgeting purposes but it must be optional. The student must not be coerced into providing the school permission to retain the funds and the student must be informed of his or herright to rescind the authorization at any time. If an institution holds excess student funds, it must? I Identify the amount of funds it holds foreach student or parent in a subsidiary ledger I account designed for that purpose; - 0 Maintain, at all times, cash in its bank account in an amount at least equal to the I amount of funds the institution holds for the student; and I 0 Notwithstanding any authorization obtained by the institution, pay any remaining balance on loan funds by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year. for which they were awarded. If a school has lost contact with a student who is due a credit balance, it must use all reasonable means to locate him or her. If it still cannot ?nd the student, the school must return the credit balance to the lender to reduce the borrower?s loan balance, or, to the appropriate Title IV program(s). Noncomplianee: procedure for obtaining astudent?s authorization to retain'Title IV Credit balance ?mds does not appear to be optional for students. Students are required to sign a form called ?Voluntary Authorization Agreement? which states I authorize Southern Technical College to initiate credit entries for ?nancial aid amounts, debit entries and any adjustment to my account." Southern Technical College OPE 03903500 201140427638 Page 18 of 2] ?If a credit balance appears on my account, I authorize the institution to determine if the credit is in excess of my tuition, fees and any other applicable charges for the completion 1 of the current loan period or award years as applicable. If this is the case and there is a true excess, I authorize the schooi to hold these funds until such time as I have earned the aid based on the Federal Return to Title IV Funds Policy.? The only preference the student can select is authorize the school to refund any credit I balance to my lender in order to reduce my overall student loan debt.? . Required Action: We also remind the institution that Title IV aid credited to a student's account may be used to satisfy current year charges (per 34 C.F.R. 668.164 If a student?s aid package includes?a Title IV loan,_the- year is the loan period. If the student does not have a loan, the year is the award year. The maximum amount of prior year charges that may be paid with current year ?inds is $200._ STC is required to revise its procedures for the payment of and authorization to retain student credit balance ?inds. The student must be given the option of having their credit balances returned to them within 14 days as stated in the regulations. Returning loan funds on behalf of the student is not a part of the cost of attendance. Further, the student must not be coerced into signing the credit balance authorization form as stated in the Institution?s policy as a required document. The policy must be in compliance with the above requirements, and, it must take effect immediately. Please provide a copy ,of your revised policy and anthorization form in response to this ?nding. Finding #13: Policy/Procedures Manual Missing Citation: To participate in the Federal Student Aid (FSA) programs, a schooi must demonstrate that it is administratively capable of providing the education it promises and properly managing the FSA programs. 34 CF. R. 668.16 Noncompiiance: STC does not currently have a policies and procedures manual that describes how all the various function described in 34 CFR 668.16 are being properly I administered. - Required Action: While the regulations do not speci?cally state that must have a policies and procedures manual, it does however state that an Institution must demonstrate that it is capable of adequately administering the program under each of the standards established in this section. The Financial Aid Director stated the manual was still in the developing stages. 3.9911139 Techaicai College . OPE 03903500 201140427638 Page 19 of 21 In response to this ?nding, STC must provide a copy of th?. manual. College OPE Ibiibi?103500 201140427638 Page 20 of 2] 20092010 Student?s Name Student Sample Student?s SSN (last four digits Only) 201012011 6 FDIRECT FDIRECT EMT s: glow (oi-6? . PSTAFFORD RD FDIRECT FDIRECT ENT DATE OF NJA DEPARTMENT OF EDUCATION EFT MESSAGE FORMAT av. ABA Number 021030004 Sender No; Sender Ref. No. Amount Sender Name inserted by the Federal Reserve Bank) Treasury Department NadeTRf TREAS NYC I AC - 91020001 Name I City I'State: DUNS I TIN: FOR: I INSTRUCTIONS A. Complete circled items 1-4 ahove as fo?ows: CD Indicate amoum including net-Lt: digits. ?Indieate Name, City, and State. 6) Indicate DUNS Number and Taxpayer Identi?cation Number (TIN). Enter the reasonfor the remittance: Bill Number 1' Document Number Other. B. Provide the sending bank with a copy of the campleteri form. This farm contains o?ier infant-Latiqu the bank win need td trammit the thus-age. FED-WIRE EFT MESSAGE FORMAT INSTRUCTIONS Page 1 of 1 Version: October 1, 2008