Top Audit Findings & Best Practices for Campuses

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Top State Audit Findings and Best Practices

The Office of the State Comptroller’s Division of State Government Accountability audits postsecondary institutions to ensure that they correctly certify students’ TAP awards and have complied with the program’s legal eligibility requirements and distributed TAP grants only to students who meet the criteria. 

The audits examine eligibility decisions and identify errors made by the institutions. School administrators, in particular the TAP Certifying Officer, maintain frontline responsibility for the program and must ensure the laws and regulations are applied correctly for each student when award tuition assistance. When errors are identified, schools are negatively impacted and can be asked to repay the State. 

Error: Certifying full-time TAP awards for students not attending full-time for award purposes.

Campuses sometimes mistakenly certify full-time TAP awards for students who are not attending school on a full-time basis for award purposes, as define by regulations. 

SUNY campuses operate on a 15 week semester basis. Many campuses have accelerated/fast track courses. Though these courses are approved by SED they do not meet the 15 week/100 day requirement as a standalone. A student must be enrolled in at least 1 course that meets the 15 wk requirement, or enrolled (at the start of the term) in two consecutive modules that together make up the 15 week/100 day requirement.

To be considered for full-time, students must enroll in courses applicable to their program of study, for at least 12 credits. Repeat courses (where a passing grade is received) do not count toward the fulltime requirement.  See HESC’s TAP Coach for additional information on repeat courses.

Best Practice: Ensuring Fulltime Status. Campus administrators must ensure students are selecting the appropriate courses to satisfy the minimum full-time requirement for State financial aid purposes - courses must count toward the completion of their degree. 

It is important for campus administrators, including academic, enrollment and financial aid to ensure consistent advice and messaging regarding applicable coursework for financial aid purposes.

If your campus uses an automated system, it is important to verify the software is correctly evaluating a student’s course load for financial aid.

Questions to Consider:

• Has the student enrolled in at least 12 credit hours? If the student is matriculated and has declared a major, do at least 12 credit hours of the courses selected count toward completion of the degree?
• Has the student been advised to enroll in more than 12 credit hours? (A lower course load is likely to be insufficient to complete a bachelor’s degree within four years. Most bachelor’s degrees require a minimum of 120 credit hours to graduate or an average of 15 credit hours per semester, which is more than the TAP minimum requirement of 12 credit hours per semester.)
• Has the student been advised that the lifetime limit of TAP is generally eight semesters for four year degrees, six semesters for two year degrees and up to ten semesters for approved five year undergraduate degrees and students in approved remedial programs? (if students understand that the number of TAP awards is limited, they may be more conscientious about completing their degree on time).
• Has the student repeated a course despite earning a passing grade the first time? 

Error: Lacking documentation for matriculated students.

Schools sometimes lack documentation that a student who has or is receiving TAP (or other State administered financial aid programs) has matriculated in an approved program of study.

Matriculation for the purpose of determining eligibility for State student financial aid is defined in State Education regulations.

Often times this documentation is collected by the Admissions office.

Best Practice: Ensure documentation is on file for matriculated students

Documentation of matriculation is required in State Education law. 

Once a student has applied and has been accepted by a campus, the campus must document that, according to its own admissions procedures and standards, as well as relevant State or federal regulations, the student has the ability to benefit from the educational program. 

The campus must also assess and account for the student’s unique academic needs and provide remediation if necessary.

The TAP Certifying Officer is responsible for ensuring these requirements are met.

Whether tracked manually or electronically, the TAP Cert officer – regardless of the office they are in – need to communicate with the office responsible for collecting documentation to ensure it is being done correctly.

HESC’s TAP Coach includes a topic that details the requirements for matriculation.

Note: For TAP purposes, campuses are not required to collect the high school requirement if the student was certified for TAP in a prior year at another school.  It is thought that the prior school did their due diligence in assessing a student’s eligibility. Even though it is not required, as a best practice campuses may want to collect the high school requirement documentation.

Questions to Consider:

• If the student attended a secondary school in the United States, does that student have valid proof of high school completion, such as high school diploma from a school registered with the SED or a certificate of General Education Development (GED) or the equivalent approved by SED?
• If the student has a high school completion credential from a school outside the United States or an individualized Education Program diploma, has the student taken an SED approved ability to benefit (ATB) test and received a passing score? 

Error: Not appropriately tracking students’ good academic standing.

Schools sometimes do not appropriately track a student’s academic progress toward receiving at degree or the required percentage a student must pursue each semester. 

Best Practice: Ensure a student’s satisfactory academic progress (SAP) and pursuit of program (POP) are being tracked properly. Many, if not all, SUNY campuses have automated the two components of good academic standing – Satisfactory Academic Progress (SAP) and Pursuit of Program (POP). Campuses should verify that their automated system is correctly evaluating SAP and POP, according to State Education Regulations, for students receiving State financial aid. 

Most full-time students in a bachelor’s degree program may receive TAP for eight semesters. The statutory limit is intended to encourage students to complete their studies in a timely manner. Campuses need to track SAP that students make toward degree completion, and determine whether students are maintaining good academic standing and will finish their studies before exhausting the allowable number of TAP grants (or other State administered financial aid). 

Once a student begins to receive TAP or other State administered financial aid, campuses should:

• Monitor the student’s achievement of certain benchmarks each term, a process that determines whether a student will remain eligible for continued State aid.
• Advise students to register for more than the 12 credit minimum.
• During an audit, a well versed campus staff should ensure the auditors understand how the campus software reflects repeat courses – so they are inadvertently cited for POP or SAP issues.

Error: Course selection is not part of an approved program and does not meet POP requirements.

During audits, State Comptroller staff have determined that some academic advisors encourage students to make choices regarding course selection that ultimately make a student ineligible for State financial aid.

 Academic advisors working in the academic interests of the student often lack familiarity with TAP laws and regulations that would help them assist students in making the right academic choices and maintain eligibility for TAP and other State administered financial aid programs.

Best Practice: Ensure academic advisors are aware of a possible impact on financial aid for financial aid recipients. Academic Advisors do not need to be experts in financial aid, but should advise students that if they are a financial aid recipient, they should speak with the financial aid office before selecting or changing courses - to ensure the academic choice they make does not impact their eligibility. Financial aid can train advisors who coach students about course and major selection to understand TAP and other State administered financial aid eligibility requirements.

Questions to Consider:

• Has the student maintained the required cumulative minimum grade point average each term?
• Has the student completed the required number of cumulative credits at the end of each term?
• Has the student completed the required number of appropriate credits (percentage of the minimum requirement) for the declared major during each term?
• Is the student registered for more than the 12 credit minimum?
  • A student will exhaust eligibility if they are only enrolling for 12 credits each term.
• Is my campus software up to date with the current standards of progress in State Education Regulations? (Higher standards can be used when approved by SED)

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Top Federal Title IV Audit Findings and Best Practices

The Higher Education Act of 1965, as amended (HEA) and Title 34 of the Code of Federal Regulations (CFR) require all institutions participating in the Federal Student Financial Assistance Programs (SFA) to have an annual financial and compliance audit performed by an independent auditor. Institutions that participate in the SFA programs frequently engage service organizations (servicers) to perform certain functions relating to the administration of the SFA Programs. The HEA and 34 CFR requires servicers to have an annual compliance audit performed of the servicer’s administration of the SFA Programs.

SUNY is one of eleven agencies included in the Single Audit for New York State, as required by OMB Circular A-133. The financial aid cluster, which includes federal grants and loans accounts for about $1.5 billion in financial aid distributed to SUNY students attending State operated campuses. All State operated campuses and the Student Loan Service Center (SLSC) are included in the audit. A handful of campuses are selected for field work, including any campuses with prior year findings. A final report is submitted to the Federal Audit Clearinghouse.

Error: Notification of Disbursement Not Sent to Student/Parent Loan Recipients.

Best practice: Ensure that all recipients receive the required notification of student/parent loan disbursements. Notices of disbursements are required within the 30 day time frame. Campuses must ensure program software is updated to issue the notifications either electronically or as a hard copy after each loan disbursement:

• At the beginning of each payment period meet with programming staff to ensure that the software programs have been updated to meet this requirement.
• After a few loans have been made, verify that the notifications have been issued timely. If not, meet with the programming team to update campus software.

Campuses should not rely on the COD for addressing the notification requirement. Schedule an annual or bi-annual meeting with programming staff, the Bursar’s office and Financial Aid to set notice of disbursement dates and spot check that they have been issued within current federal guidance timeframes.

Question to consider:

• Has the campus software program been updated to send student loan notifications within the required federal timeframes? 

Error: Return of Title IV Funds (R2T4) Not Timely.

Though the Office of Financial Aid may not be performing this task, the office is responsible to ensure the return of funds is timely. 

Best Practices: Periodically review and revise, as necessary, policies and procedures to ensure the return of Title IV funds is within 45 days of when the student withdraws from campus. Findings can be minimized by a coordination of efforts and shared information between Academic Advisement, Bursar, Registrar, and Financial Aid offices. The development of a R2T4 monitoring system and R2T4 calculations training for staff are best practices to meet the required return timeframe. 

Students who receive Title IV financial aid may need to return all or a portion of these funds when reducing course load or withdrawing from campus. Students who indicate they may make changes to their course load or withdraw should be advised to see a financial aid counselor to discuss the possible financial aid impact and resulting liability owed to the college. 

For unofficial withdrawals, campuses should establish a formal process to determine the date of last documented academic activity to determine the date of withdrawal. Campuses should consider monitoring the date of last attendance, date of last completion or submission of an assignment and the date of last contact with an academic advisor. Indications of other absences on campus may signal an unofficial withdrawal and offer an opportunity for a campus official to reach out to a student.

Questions to consider:

• Does the refund policy identify the requirements for the Title IV funds?
• Are the requirements and procedures for unofficial and official withdraws from school made available to all students and administrators (Bursar, Registrar, Academic Advising, Academic Department, and Financial Aid Office)?
• Are students required to meet with their Financial Aid advisor when dropping classes or officially withdrawing from school?

Error: Student Enrollment Reporting not timely.

Student data transfers from the college to the Clearinghouse and NSLDS were found not to be consistent and out of compliance.

Best Practices: Ensure transmission dates to the National Student Clearinghouse (NSC) are set properly

• Transmit the changes to NSC every 30 days.
• Ensure campus data reflecting student status changes is transmitted to the NSC within 60 days of student changes, as required.
  • If your Campus sets a 60 day schedule, be aware of NSLDS reporting dates so that poor timing does not create a lag.
  • Status changes can be at specific points during the semester, after: add/drop date, last day to withdraw date, end of semester date, or monthly. The Registrar should work with the programming team to ensure all Student Status Confirmation dates are set for each semester.   

Questions to consider:

• Has the campus had issues with the NSLDS not receiving data from the NSC?
• Are all student data fields updated based on NSC changes?
• Has your campus periodically tested to ensure the data is sent within the 60 day status change reporting requirement?
• Who does the Clearinghouse alert when there are errors on the data transmission? 

Other TAP Eligibility Requirements the Comptroller’s Audits Examine

Residency

• To be considered a State resident for purposes of TAP and other State administered financial aid programs which require the student to be a NYS resident, a student must legally reside in the State for one year before attending a campus or have been a legal resident during the last two semesters of high school. 
  • The legal residence, for award purposes, of a dependent student is that of the custodial parent
  • The legal residence is sometimes established by submitting documentation that demonstrates a student or his or her parent(s) have a permanent address in the State, which could include a lease, a tax return, a utility bill or driver’s license.

Tuition

• Error: Campus reported tuition amounts in excess of actual charges.
• Best Practice: Campuses are responsible for reporting to HESC the amount of tuition incurred by students, a figure used to calculate TAP awards.  Students who have a reduced liability to the school may have a reduction in the amount of tuition owed and the reduced amount should be reflected in the reporting to HESC.
• Error: Audits have found that some schools fail to credit student’s accounts with their TAP awards, and as a result, the students do not receive the benefit of the awards.
• Best Practice: Campuses are expected to act on a timely basis in crediting a student’s account with a TAP payment. 

Required Deferment of Tuition

HESC requires schools to defer term tuition charges in an amount equal to the award when students present valid award notification for a TAP or other state award for that term, or if the student's award appears on an institution payment roster for that term.
Exceptions: Schools are not required to defer tuition based on an award notification or payment roster when:

• the campus reasonably believes the student may be ineligible for the award or that the award amount may be reduced; or
• the campus is waiting for the student to complete or correct financial aid forms that could affect the student's eligibility for an award or the award amount; or the institution is waiting for income verification.
  

Suggested Deferment of Tuition

In the absence of an award notification, campuses are encouraged to defer term tuition charges:

• when the institution can determine that the student is eligible for an award for the term and the amount of the award by using HESC's School Inquiry Services, or
• by referring to a student status list.

Crediting of Awards

HESC requires schools to credit student accounts with any state student financial aid payments or prepayments within seven calendar days of when the student incurred a full tuition liability for the term; or within seven days of when the school receives such payment or prepayment check, whichever is later.

Disbursement of Funds

The institution should disburse any state student financial aid awards to the student as soon as possible, but not more than 45 days after the institution has credited the award to the student's account.

Exceptions: Instead of disbursing funds, schools may credit them toward a future term if the student authorizes the credit in writing. Schools may also credit state student financial aid payments toward charges the student has incurred for a future term. That term must already be underway when the school receives the payment, and the balance for that term must exceed the amount deferred for that term based on anticipated receipt of a state award.

Declaring a Major

NYS Education Law requires a student to be matriculated in an approved program (major) to be eligible for State student financial aid.  Although a strict interpretation would require students to be enrolled in an approved program from their first semester to be eligible for aid, the State agencies involved with student aid have agreed that students enrolled in two-year or four-year degree programs can defer declaring a major and still be eligible. This agreement was reached based on the understanding that in their first and second years, students generally take courses that are applicable to a number of approved programs at the institution.

• Students enrolled in two-year academic programs leading to associate degrees must declare a major no later than within 30 days of the end of the institution’s add/drop period in the first term of their sophomore year.
• Students enrolled in four-year academic programs leading to baccalaureate degrees must declare a major no later than within 30 days of the institution’s add/drop period in the first term of their junior year.