4.7 Title IV Program Responsibilities

Federal Requirement 4.7: Title IV Program Responsibilities

The institution is in compliance with its program responsibilities under Title IV of the most recent Higher Education Act as amended. (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.)

Compliance Partial Compliance Non-compliance

NARRATIVE

Financial aid at the University of South Florida Sarasota-Manatee (USF Sarasota-Manatee) is administered as a USF System function. To serve those students who declare USF Sarasota-Manatee as their home campus within the USF System, the Financial Aid unit within Admissions & Financial Aid on campus serves as a liaison to the USF System Office of University Scholarships & Financial Aid Services. The Assistant Director of Financial Aid is USF Sarasota-Manatee’s liaison to the USF System office in Tampa. with the assistance of a Financial Aid Advisor and a Financial Aid Specialist (Financial Aid Staff).  All three (3) assist USF Sarasota-Manatee students with the aid application process, as well as with the processing of aid in accordance with each student’s established eligibility, whether the student is taking courses on the Sarasota, North Port, or Tampa instructional sites or studying online from a distance. During fiscal year 2014-2015, USF Sarasota-Manatee home campus students received approximately $16,687,853 in Federal aid.

The United States Department of Education authorizes the institutions within the USF System, including USF Sarasota-Manatee, to participate in the Federal Title IV programs under the Federal Student Aid Program Participation Agreement, which is valid through March 31, 2018.  The Department of Education has had no disputes with the USF System’s administration of Title IV aid programs. No complaints have been filed against the System, and no impending litigation issues have arisen with respect to financial aid activities. None of the institutions within the USF System owe any reimbursement of funding to the Department of Education.

In accordance with Title IV Student Aid Program regulations, USF Sarasota-Manatee adheres to all federal regulations in processing student aid applications and federal funds. Financial aid officers verify student eligibility and carry out verification regulations as mandated by federal and state regulations. Financial aid officers review regulations each year and adjust both manual and systematic verification procedures. The Office of University Scholarships & Financial Aid Services  reviews and updates policies and procedures for review of eligibility and awarding of aid. It maintains these online on its USF System Financial  Aid Policies and Procedures Electronic Manual to permit up-to-the minute changes and notices. The manual includes established procedures for cost-of-attendance calculations, methodology for awarding of aid, determination of satisfactory progress, and other procedures required to comply with federal, state, and institutional financial aid awarding.

The Florida Auditor General, in accordance with the United States Office of Management and Budget (OMB) requirements, conducts an annual audit of the federal award programs of the state of Florida, including financial aid programs administered by the state universities. As part of the USF System, USF Sarasota-Manatee is included in the most recent audit of the USF System Title IV HEA Financial Aid Programs. In the March 2015 OMB A-133 Report, the USF System had one finding related to the Treatment of Title IV Funds When a Student Withdraws: 2014-060, “the institution did not always maintain documentation evidencing that the date reported by faculty was correct. In some cases, this led to the institution not performing a calculation when required.” USF Sarasota-Manatee were not the faculty who were not always maintaining this documentation; the finding related to faculty at a different institution within the USF System.

The USF System instituted corrective action in response to this finding. As noted in the report:

1. Continue outreach to faculty to ensure the Last Date of Class Attendance is
properly recorded for institutional record-keeping and auditing purposes.
2. Educate faculty on the importance of reporting the last date there was
academic activity when submitting grades for students who receive unofficial
withdrawal grades, as opposed to merely providing the last date a student attended class or
logged in.
3. Implement a change to myUSF e-Grades that allows faculty to clearly indicate
when a student “Never Attended” class for Federal financial purposes (i.e. did not
engage in any academic activity during the semester).
4. Investigate the future purchase of drop-out detection software to document the
date of last academic activity, if cost effective, in the FY 2015-16; this will
alleviate the responsibility expected of faculty to report a last attended date for ~9,000
students annually.

 As of this date, the USF System has no outstanding issues with the Department of Education with regard to the administration of Title IV programs, and no known complaints have been filed with the Department of Education regarding the administration of Title IV programs. The USF System has not been placed on reimbursement, nor has it been required to obtain a letter of credit in favor of the Department of Education. University Scholarships and Financial Aid Services submits all required reports to the Department of Education in a timely manner and expects that the next OMB report, to be issued in March 2016, will have no findings.

In the March 2014 report (March 2014, OMB A-133 Report), the USF System had no findings.  The State of Florida Auditor General’s reports do not list institutions with no findings; therefore, the USF System does not appear in the March 2014 OMB 133 Circular.

University Scholarships and Financial Aid Services provides a comprehensive program to assist students with the necessary financial resources to enroll at and graduate from all three USF System institutions. In addition to Title IV aid programs, University Scholarships and Financial Aid Services administers state, institutional, USF Foundation, and private scholarships and grants. In all aspects of its financial aid operations, the USF System complies with statutory and regulatory requirements, as required by the Department of Education. The Department of Education conducted a program review in July 2010. One finding was noted and resolved by providing documentation that the USF System was in fact in compliance, and USF received an expedited Final Program Review Determination Letter in September 2010.

Further information on audits of financial aid programs is provided in Comprehensive Standard 3.10.2 (Financial Aid Audits).  

SUPPORTING DOCUMENTATION AND EVIDENCE

 

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