The Fifth-Year Interim Report

Part III: The Fifth-Year Compliance Certification


4.7 Title IV Program Responsibilities

The institution is in compliance with its program responsibilities under Title IV of the 1998 Higher Education Amendments. (In reviewing the institution’s compliance with these program responsibilities, the Commission relies on documentation forwarded to it by the U.S. Department of Education.)

Judgment of Compliance

Compliance

Narrative

As documentation forwarded by the U.S. Department of Education will verify, Alcorn State University (ASU) is in compliance with its Title IV program responsibilities.   The Department of Education Atlanta School Participation Team has determined that the University has qualified to participate in programs under the Higher Education Act of 1965, as amended (HEA) and the Federal student financial assistance programs (Title IV, HEA programs). See the attached Program Participation Agreement and Eligibility and Certification Approval Report (ECAR). The university has received approval to participate in Federal Student Financial Aid Programs through March 31, 2017. The university has a reapplication date of December 31, 2016, and has not received a response from the Department of Education.

ASU has submitted a response on July 23, 2016 to the fifteen findings in the latest Program Review Report. To date, the Department of Education has not issued a final program review determination letter. To view ASUs response to each of the findings, click on the finding in the chart. Also, a summary response to each of the fifteen findings is listed in the chart.

Finding

Alcorn State University Response (Summary)

1- Lack of Administrative Capacity

ASU has reviewed its policies and procedures and has enhanced them to comply with the requirements under 34 C.P.R. Part 668. ASU showed evidence of improvement in administrative capability by responding to the issues cited in the report.

2- Discontinued Participation in Federal Perkins

ASU has reconciled the open loan report. The university will be submitting payment, engaging an auditor and closing out all Perkins loan this fiscal year.

3- Incentive Compensation Violation Citation

ASU did not agree with this finding. Under the former president, ASU established what was believed to be a new scholarship program. Only institutional funds were used to support the scholarship. The program has been discontinued.

4- Crime Awareness Requirement Not Met

ASU did prepare, publish, and distribute an accurate and complete 2014 ASR in accordance with Federal regulations. The report was published before October 1 and post cards to the entire campus community and made available on the ASU website on October 1.

5- Drug and Alcohol Abuse Prevention Program Requirements Not Met

The university has employed a new Director of Counseling Services, a biennial review was completed fall 2016 semester. The director will provide the proper reporting of data, and recommendation to improve the program.

6- Incorrect Expenditure/Reporting on FISAP

The Pell Grant expenditure was accidentally reported as $12, 360,658 in 2013-2014. The correct amount of $11,856,420 was sent on June 15, 2016. The request was approved.

7-Excess Interest Maintained on Program Funds

Funds were moved from NIH bank account on May 15 2015. The funds were due to drawdowns not being moved from previous years for SEOG, Pell, and Work Study.

8-Return to Title IV (R2T4) Made Late/Calculation Error

ASU adjusted the policies and inter-office procedures for processing the Return of Title IV Funds (R2T4s).

9- Ineligible Student Not Making Satisfactory Academic Progress (SAP)

ASU does not agree with this finding. ASU reviewed student #9 file, and after review, ASU determined that the SAP was monitored and accurately evaluated.

10- Exit Counseling Deficiencies

ASU has established controls, updated policies and procedures that ensure compliance with the requirements of exit counseling of the student financial assistance program, including ongoing staff

training and enhanced record maintenance.

11- Verification Violations-Verification Status Codes Incorrectly Reported

ASU did not select students #1, #7, #10, #13, and #34 for CPS verification. A technical glitch occurred that prevented updating students not selected for verification, so the code “V” was used. ASU has updated non-selected students starting with the 15-16 award year to reflect the appropriate verification code of blank and only use V if verified because student was selected for verification or the institution selected for verification with all verification documents reviewed and place in a file.

12- Student Status Confirmation Report-Late/Incorrect Reporting

ASU revised its Enrollment Reporting Policy/Procedures to ensure future compliance. ASU has restructured the Registrar’s office and assigned dedicated personnel to ensure that reporting is done timely and accurately.

13- Inaccurate Record Keeping

ASU disagrees with this finding. ASU uses the Banner system, which is used by many colleges and universities to find that everyone runs the same process. 

14- Financial Need Incorrect

ASU created a Quick-Flow program in Banner along with Auto-Packaging to ensure this oversight does not happen in the future.

15- Consumer Information Missing/Inadequate

ASU disagreed with this finding. A Consumer information/Disclosures website link was provided to the DOE as stated.


To the university's knowledge, there have been no complaints filed with the Department of Education. However, there was a student complaint regarding financial aid status brought to the attention of the president. The case has been resolved satisfactorily; no institutional error was found in the case. There are no significant impending litigation issues with respect to the Office of Financial Aid, and the university does not owe any unpaid dollar amounts to the Department of Education.


The university has not been placed on the reimbursement method, nor has it been required to obtain a letter of credit in favor of the U.S. Department of Education. The university is not aware of any infractions that would jeopardize its Title IV funding. The audited A-133 financial statements which are conducted annually for the university do not evidence any Title IV noncompliance issues.

Full audit statements for FY14, FY15, and FY16 are attached.

For 2011-2013, ASU’s Official 3 Year Cohort Default Rates (CDR) is as follows:

  • 2011 CDR— 15.7%
  • 2012  CDR—15.5%
  • 2013 CDR—17.9%

 

ASU has continued to keep its default rate well below 30%. Effective September 2014, any time two of a school's three most-recent 3-year rates equal or exceed 30 percent, the school may be placed on provisional certification for Title IV participation.


TextTitle 
Program Participation Agreement Program Review Report
Eligibility and Certification Approval Report (ECAR) ECAR
1- Lack of Administrative Capacity DOE_Finding 1_Lack of Administrative Capability
2- Discontinued Participation in Federal Perkins DOE_Finding 2_Discontinued Participation in Federal Perkin
3- Incentive Compensation Violation Citation DOE_Finding 3_Incentive Compensation Violation Citation
4- Crime Awareness Requirement Not Met DOE_Finding 4_Crime Awareness Requirements Not Met
5- Drug and Alcohol Abuse Prevention Program Requirements Not Met DOE_Finding 5_Drug and Alcohol Abuse Prevention Program Requirements Not Met
6- Incorrect Expenditure/Reporting on FISAP DOE_Finding 6 Incorrect Expenditure_Reportin on FISAP
7-Excess Interest Maintained on Program Funds DOE_Finding 7_Excess Interest Maintained On Program Funds
8-Return to Title IV (R2T4) Made Late/Calculation Error DOE_Finding 8_Return to Title IV R2T4 Made Late Calculation Error
9- Ineligible Student Not Making Satisfactory Academic Progress (SAP) DOE_Finding 9_Ineligible Student Not Making Satisfactory Academic Progress SAP
10- Exit Counseling Deficiencies DOE_Finding 10_Exit Counseling Deficiencies
11- Verification Violations-Verification Status Codes Incorrectly Reported DOE_Finding 11_Verification Violations Verification Status Codes Incorrectly Reported
12- Student Status Confirmation Report-Late/Incorrect Reporting DOE_Finding 12_Student Status Confirmation Report Late Incorrect Reporting
13- Inaccurate Record Keeping DOE_Finding 13_Inaccurate Record Keeping
14- Financial Need Incorrect DOE_Finding 14_Financial Need Incorrect
15- Consumer Information Missing/Inadequate DOE_Finding 15_Consumer Information Missing Inadequate
case Financial Aid Appeal
FY14 FY2014 Audit Report
FY15 FY2015 Audit Report
FY16 FY2016 Audit Report