1. Top 10 (But Really There’s 13) State Audit & Program Review Findings (And How To Avoid Them In the Future!) Presented by Robert Helgeson Audit Manager for the Office of Higher Education

2. About the Data Covers findings, recommendations, and comments From fiscal years 2006 through 2014 (only closed audits to date for 2014) Summarized into categories--findings can cover more than one aid program Methodology is based on number of school occurrences per category Does not include University of Minnesota, one for-profit, and one non-profit as they use external CPAs 2

3. Category: Close Out Issues End of year close out for MSG, CCG, SWS and sometimes MGIB & MISP Year end refunds and reports due to OHE received at least one week late Errors in year-end reports—rounded earnings, MISP not returned within 30 days, data elements on reports not matching to audited data 147 school units, tracking since 2012, no under awards, $24K of over awards 3

4. Category: Units Not requesting or obtaining transcripts Incorrect evaluation of transcripts Double counting units Including PSEO & CEU credits Semester vs. quarter units vs. clock hours Missed consortium credits Combining multiple schools during one term to arrive at more than max term Not counting “W” grades Paid beyond or did not pay eligible units 222 school units, $53K of under awards, $1.065 million of over awards 4

5. Category: Calculation Inputs CCG-use of incorrect hourly cap, actual costs of care, weeks of care, weeks in term, # of credits, FTI, HH size, receipt of MFIP or other, missed consortium credits, split between multiple providers, use of wrong year award chart 147 school units, $45K of under awards, $62K of over awards 5

6. Category: Certification Issues SELF—COA/EFA/LP not in sync, did not include work study or fed loans, grade level, $7,500 vs. $10,000 based on program, two loans in one year, student in default on fed or other loans, no doc of max effort test, no SAR on file, no doc of how cert calculated SWS—no COA to verify need or COA did not match to enrollment level, awarded in excess of need CCG—unable to confirm provider verification completed 143 school units, no under awards, $77K of over awards 6

7. Category: Enrollment Levels MSG—paid at incorrect level at date of disbursement including calculation of average clock hours, includes paying after student w/d during a term or after a term paying for “W” grades, incorrect pro-ration for final clock hour term CCG—similar to MSG SWS-paid at less than half-time without doc of student’s intent to enroll at least half-time in next term or dropped courses to less than half-time during a term SELF—disbursed at less than half-time MISP—disbursed at less than three-quarter time for undergraduates 143 school units, $34K under awards, $99K over awards 7

8. Category: Eligibility Issues Non-resident—paid to non-Minnesota residents—77 school units, no under and $201K of over awards Other – MSG: no FAFSA filed, did not confirm eligibility and failed to pay eligible students, eligible non-citizen not paid for all terms, did not pay for summer based on required additional form, paid while on child support hold, paid while not making SAP 8

9. Category: Eligibility Issues (Continued) Other (continued) – CCG: child turned 13 but still paid, 10% infant adjustment used incorrectly – SWS: allowed to work beyond need – MGIB: paid to students not meeting eligible veteran status, paid from incorrect fiscal year 82 school units, $49K under and $49K over awards 9

10. Category: Policy Issues SAP Policy—not in compliance with updated federal requirements, not following stated policy—97 school units, no under awards, $22K of over awards Refund Policy-policy does not include reference to MN calculations or requirements (MS 141), includes MN aid in federal distribution list, holding credit balances—62 school units, no under awards, $150 over awards Other Policies—no written definition of grade levels, no doc on file of CCG award notices or not done, no LOA policy or not following policy, student accounts not accurate or inadequate, no electronic capability to interact with OHE, late reporting of DDS records to OHE—62 school units, $2K of under and $25K of over awards 10

11. Category: Reconciliation and Update Issues Required reconciliations not available at time of audit or were inaccurate Programs with no reconciliation requirements, data provided on year-end reports do not match to student data Cash received for programs but not disbursed and not returned to OHE MGIB and MISP documentation not updated based on changes in COA and/or aid received (e.g. federal veterans’ funding or tribal scholarships) 129 school units, $6K of under and $49K over awards 11

12. Category: Verification and Conflicting Data Resolution Verification not done, not completed, or not transmitted to CPS Omissions in untaxed income or other oversights in verification process C codes not resolved or doc on file for citizenship and defaulted loans Conflicting information not resolved prior to award and disbursement including new ISIR with same EFC but dependency status changed 91 school units, $3.5K of under and $63K of over awards 12

13. Category: Refund Calculation Issues OHE aid refund process not done or done incorrectly Not posting results of refund calculations to student accounts 84 school units, $35K of under and $84K of over awards 13

14. Category: Other Award Issues MSG-used the incorrect budget (2 year vs. 4 year), did not disburse any MSG during the term, disbursed before start of clock hour term, award amount not equal to posted to student account CCG-not awarded per priority policy MGIB-used incorrect budget, calculation done for incorrect number of terms SELF—amount received via EFT not fully disbursed to student account, disbursed more than 30 days after EFT 83 school units, $37K of under and $25K of over awards 14

15. Category: Late and Incomplete Applications Late—FAFSA not filed within 30 days of beginning of term for MSG, MGIB application not filed by end of term Incomplete—for CCG, not all questions answered on application or provider verification section not completed 18 school units, no under and $14K of over awards 15

16. Category: Reciprocity Issues Included student on a year-end report who did not attend Included tech students on report when they should be excluded Charged incorrect tuition amount (over and under) 18 school units, $500 of under and $6K of over awards 16

17. More About the Data-In Total Sector School Units: FY 06 to FY 14 % Under Awards% Over Awards% MnSCU- Four Year 734%$8,5973%$26,8391% MnSCU- Two Year 38222%36,14314%191,64110% For Profit 86650%145,36555%725,70739% Non Profit 42424%74,33928%918,80349% Totals1,745100%$264,444100%$1,862,990100% 17

18. Still More About the Data-Totals Sector# of Institutions as of FY 14 % of Total Institutions % of OHE Aid in FY 14 School Units FY 06- FY 14 % of All School Units U of MN43%25%00% MnSCU- Four Year 75%19%734% MnSCU- Two Year 3023%20%38222% For Profit 5844%8%86650% Non Profit 3425%28%42424% Totals133100% 1,745100% 18

19. Questions? Call Robert at (651) 259-3997, send a message to robert.helgeson@state.mn.us OR contact the OHE program managers for more information about the programs robert.helgeson@state.mn.us 19