Prepared for

Calvin University

OPE ID: 00224100

PRCN: 202010330103

Prepared by
U.S. Department of Education
Federal Student Aid
School Participation Division – Philadelphia/DC & Chicago

Final Program Review Determination

September 3, 2020

The Wanamaker Building

100 Penn Square East, Suite 511
Philadelphia, PA 19107
StudentAid.gov.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 2

Table of Contents

Page

A. Institutional Information 3

B. Scope of Review 4

C. Final Determinations 5
Resolved Findings/Findings Without Liabilities
Finding #1: Return To Title IV Calculation Errors
Finding #2: National Student Loan Disbursement System Reporting Inaccurate
Finding #3: Policy for Monitoring Unclaimed Title IV Balance Checks
Inadequate
Finding #4: Loan Period Does Not Equal Period of Enrollment
Finding #5: Common Origination and Disbursement System Reporting
Inaccurate
Finding #6: Title IV Credit Balance Policy Inadequate
Failure to Have a Written Authorization to Hold a Title IV Credit
Balance
Finding #7: Failure to Notify Students of Availability of Consumer
Information/Consumer Information Inadequate
Finding #8: “Federal Funds” Not In Title of Bank Account

D. Appendices 10
A. Program Review Student Sample
B. Program Review Report
C. Institution’s Initial Written Response
D. Institution’s Second Written Response
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 3

A. Institutional Information

Calvin University
3201 Burton Street Southeast
Grand Rapids, Michigan 49546-4388

Type: Private, Non-Profit

Highest Level of Offering: Masters or Doctoral Degree

Accrediting Agency: North Central Association of Colleges and Schools

Current Student Enrollment: 3,570 (Fall 2019)

% of Students Receiving Title IV: 42% (Fall 2019)

Title IV Participation:

2017-2018
Federal Pell Grant Program $3,222,351.00
William D. Ford Federal Direct Loan Program $14,600,624.00
Federal Perkins Loan $0.00
Federal Supplemental Educational Opportunity Grant $628,304.00
Federal Work Study $1,138,490.00

Default Rate FFEL/DL: FY2016 2.4%

FY2015 2.7%
FY2014 2.1%

Default Rate Perkins: FY2017 7.3%

FY2016 11.4%
FY2015 17%
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 4

B. Scope of Review

The U.S. Department of Education (the Department) conducted a program review at

Calvin University (Calvin) from November 18, 2019 to November 20, 2019. The review
was conducted by Ms. Mónica N. Aviña, Ms. Gwen Deurell, and Ms. Jean Brennan.

The focus of the review was to determine Calvin’s 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 Calvin’s policies and
procedures regarding institutional and student eligibility, individual student financial aid
and academic files, attendance records, student account ledgers, and consumer
information requirements.

An initial sample of 15 files was identified for review from the 2018-2019 award year.
The student files were selected randomly from the list of students who 1) withdrew or
ceased attendance for any reason other than graduation; 2) were selected for verification;
and 3) received all non-passing grades (“0” GPA) for any term within the award year
being reviewed. Appendix A identifies the students whose files were examined during
the program review.

The Department issued its Program Review Report (PRR) on January 7, 2020. Calvin
submitted its first written response to the PRR on March 4, 2020, included in Appendix C.
The institution submitted a subsequent response on March 25, 2020, included in Appendix
D.

Disclaimer:

Although the review was thorough, it cannot be assumed to be all-inclusive. The absence
of statements in the report concerning Calvin’s specific practices and procedures must not
be construed as acceptance, approval, or endorsement of those specific practices and
procedures. Furthermore, it does not relieve Calvin of its obligation to comply with all of
the statutory or regulatory provisions governing the Title IV, HEA programs.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 5

C. Final Determinations

Resolved Findings/Findings without Liabilities

Finding #1: Return of Title IV (R2T4) Calculation Errors

Calvin did not include institutional charges that were assessed; rather, it included
components from the student’s budget for tuition, fees, and room and board in the
calculation. Also, the institution included the budgeted room and board component for
students who lived off-campus and were not assessed room and board charges.

Calvin was required to conduct a file review of all students who withdrew during the
2018-2019 award years and perform correct R2T4 calculations.

Calvin submitted its response March 4, 2020. With its response, the institution
submitted the results of its file review and its updated policies and procedures. The
Department reviewed the documentation and identified that the institution did not include
assessed tuition and fees originally charged to the student’s ledger account; rather it
included the adjusted tuition and fees resulting from the student’s withdrawal from the
institution for 19 students.

Calvin was required to conduct a second review of the 19 students whose calculations
were performed with adjusted tuition and fees. The institution was required to include
assessed tuition and fees originally charged to the student’s ledger account in its revised
R2T4 calculations.

Calvin submitted its subsequent response on March 25, 2020. The Department reviewed
the documentation and has accepted the institution’s response.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

Finding #2: National Student Loan Disbursement System Reporting Inaccurate

Calvin did not report accurate enrollment status information to NSLDS. For students
who withdrew, the institution updated the enrollment status information to indicate the
student’s status: 1) changed from Full Time to Half Time or Less Than Half Time as of
the effective date that the student withdrew; and 2) withdrew with an effective date as of
the end of the semester.

In addition, Calvin did not report enrollment status information to NSLDS timely.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 6

Calvin was required to conduct a file review of all students who participated in the Title
IV programs and who were enrolled in the 2018-2019 award years to determine that: 1)
the enrollment status information was reported accurately to NSLDS during the 2018-
2019 award year; 2) if necessary, to update the most current enrollment status
information to accurately reflect the correct enrollment status and 3: identify students
whose enrollment status information was reported late to NSLDS.

Calvin was also required to update its policies and procedures to ensure that enrollment
status information is reported accurately and timely.

Calvin submitted its response March 4, 2020. With its response, the institution
submitted the results of its file review and its updated policies and procedures. The
Department reviewed the documentation and has accepted the institution’s response.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

Finding #3: Policy for Monitoring Unclaimed Title IV Balance Checks Inadequate

Calvin’s policy for the return of unclaimed Title IV credit balance funds was inadequate
as it did not contain a provision to return unclaimed Title IV credit balance funds to the
Department within 240 days.

During the on-site visit, Calvin provided the Department a spreadsheet that identified 35
students with unclaimed credit balance checks. Subsequent to the on-site visit, the
institution provided the Department with billing statements for these students. The
Department reviewed the billing statements and did not identify any students whose
unclaimed checks were Title IV credit balances.

Also, Calvin provided the Department with its updated policies and procedures. The
updated policies and procedures should ensure that unclaimed Title IV credit balances are
returned to the appropriate Title IV program on the student’s behalf within 240 days.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

Finding #4: Improper Loan Origination/Loan Period Not Equal to Period of

Enrollment

Calvin originated William D. Ford Federal Direct Loans (Direct Loan) with a loan period
that did not agree with the institution’s established period of enrollment.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 7

The academic periods of enrollment established by the institution for the 2018-2019
award year was:

Full Year: September 4, 2018 to May 16, 2019

Fall Only: September 4, 2018 to December 18, 2018
Spring Only: January 3, 2019 to May 16, 2019

Subsequent to the on-site visit, Calvin submitted the Department a spreadsheet which
identified 95 students whose loan periods did not agree with the period of enrollment.
Calvin was required to correct the loan period dates to match the period of enrollment
and provide documentation confirming that the loan period was updated with its response
to the Program Review Report.

Calvin was also required to review its policies and procedures to ensure they were
sufficient to prevent a recurrence of this finding.

Calvin submitted its response March 4, 2020. With its response, the institution
submitted documentation that the loan periods were adjusted to reflect that the loan
period was updated to agree with the period of enrollment. The institution also submitted
its updated policies and procedures. The Department reviewed the documentation and
has accepted the institution’s response.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

Finding#5: Inaccurate Common Origination and Disbursement (COD) Reporting

Calvin did not report accurate disbursement information to COD for one student during
the 2018-2019 award year.

Calvin was required to adjust the COD disbursement records for Student #9 to reflect the
correct disbursement date for the Subsidized and Unsubsidized Direct Loan funds of
October 18, 2018.

Calvin was also required to review its policies and procedures to ensure they are
sufficient to prevent a recurrence of this finding.

Calvin submitted its response March 4, 2020. With its response, the institution indicated
that the student’s COD record had been updated. The Department reviewed COD and
has verified that the records had been updated. The institution also submitted its updated
policies and procedures. The Department reviewed the documentation and has accepted
the institution’s response.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 8

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

Finding #6: Title IV Credit Balance Policy Inadequate

Failure to Have a Written Authorization to Hold a Title IV Credit
Balance

Calvin’s Credit Balance Policy was inadequate as it allowed students or parents to

request a credit balance to be held but did not include information concerning this request
(whether a Title IV Credit Balance or a Non-Title IV Credit Balance) in its policies and
procedures.

Calvin was required to update its credit balance policies and procedures to include the
regulatory information pertaining to Title IV credit balances. The institution was also
required to develop a written Authorization to Hold form for student or parents to submit
when requesting that a Title IV credit balance be held.

Calvin submitted its response March 4, 2020. With its response, the institution submitted
a copy of its Authorization to Hold a Title IV Credit Balance form, as well as a copy of
its policies and procedures. The Department reviewed the documentation and identified
the Authorization Form and the policies and procedures did not contain all regulatory
requirements.

Specifically, the policies and procedures did not indicate that any remaining balance on
loan funds must be delivered by the end of the loan period and any remaining other Title
IV program funds by the end of the last payment period in the award year for which they
were awarded.

Calvin was required to revise its Authorization to Hold a Title IV Credit Balance form
and its policies and procedures to include that any remaining balance on loan funds must
be delivered by the end of the loan period and any remaining other Title IV program
funds by the end of the last payment period in the award year for which they were
awarded.

Calvin submitted its subsequent response on March 25, 2020. The Department reviewed
the documentation and has accepted the institution’s response.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 9

Finding #7: Failure to Notify Students of Availability of Consumer Information

Consumer Information Inadequate

Calvin did not deliver an annual notification to students of the availability of its consumer
information.

Also, Calvin’s consumer information did not contain all required elements as set forth in
federal regulations. The institution’s consumer information did not include:

• A statement that a student’s enrollment in a program of study abroad approved for

credit by the home institution may be considered enrollment at the home
institution for the purposes of applying for assistance under the Title IV, HEA
programs; and

• A notice that Direct loan information will be submitted to the National Student
Loan Data System (NSLDS) and will be accessible by guarantee agencies,
lenders, and institutions determined to be authorized users of the data system.

Calvin submitted its response March 4, 2020. With its response, the institution indicated
that its consumer information had been updated. The Department reviewed the
institution’s web-site and has verified that the consumer information had been updated.

The Department notified Calvin on March 12, 2020, that the Department reviewed its
updated consumer information and accepted the university’s response. The institution
was instructed to notify its students of the availability of consumer information and
provide the Department with documentation of its delivery.

Calvin submitted to the Department documentation verifying that students were notified
of the availability of its consumer information on March 25, 2020.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

Finding #8: Federal Funds Not Identified in Depository Account Title

Calvin did not identify that its bank account included Title IV, HEA program funds. The
institution’s bank account title does not contain the phrase “Federal Funds” as required
by federal regulations.

Subsequent to the on-site visit, Calvin provided adequate documentation to the

Department that its depository account now contains the phrase, “Federal Funds” in the
bank account title.
Calvin University
OPE ID: 00224100
PRCN: 202010330103

Page 10

The Department reviewed the documentation and has accepted the institution’s response.

Calvin has taken the corrective actions necessary to resolve this finding of the Program
Review Report. Therefore, this finding may be considered closed.

D. Appendices

Appendices A-D contain personally identifiable information and will be emailed to

Calvin University as an encrypted WinZip file using Advanced Encryption Standard,
256-bit. The password needed to open the encrypted WinZip file(s) will be sent in a
separate email.
Prepared for

Calvin University

OPE ID: 00224100

PRCN: 202010330103

Prepared by
U.S. Department of Education
Federal Student Aid
School Participation Division-Philadelphia/DC & Chicago

Program Review Report

January 7, 2020

The Wanamaker Building

100 Penn Square East, Suite 511
Philadelphia, PA 19107
StudentAid.gov
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 2

Table of Contents
Page
A. Institutional Information…………………………………………………………. 3

B. Scope of Review………………………………………………………………….. 4

C. Findings…………………………………………………………………………... 4
Finding #1: Return to Title IV Calculation Errors……………………………… 5
Finding #2: Policy for Monitoring Unclaimed Title IV Balance Checks 7
Inadequate………………………………………………………….
Finding #3: National Student Loan Disbursement System Reporting Inaccurate 10
Finding #4: Loan Period Does Not Equal Period of Enrollment……………….. 11
Finding #5: Common Origination and Disbursement System Reporting 12
Inaccurate…………………………………………………………...
Finding #6: Title IV Credit Balance Policy Inadequate………………………… 13
Finding #7: Failure to Notify Students of Availability of Consumer 15
Information/Consumer Information Inadequate……………………
Finding #8: “Federal Funds” Not In Title of Bank Account……………………. 16

D. Appendices 17
Appendix A: Student Sample
Appendix B: Finding #4 Student List
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 3

A. Institutional Information

Calvin University
3201 Burton Street Southeast
Grand Rapids, Michigan 49546-4388

Type: Private, Non-Profit

Highest Level of Offering: Masters or Doctoral Degree

Accrediting Agency: North Central Association of Colleges and Schools

Current Student Enrollment: 3,570 (Fall 2019)

% of Students Receiving Title IV: 42% (Fall 2019)

Title IV Participation:

2017-2018
Federal Pell Grant Program $3,222,351.00
William D. Ford Federal Direct Loan Program $14,600,624.00
Federal Perkins Loan $0.00
Federal Supplemental Educational Opportunity Grant $628,304.00
Federal Work Study $1,138,490.00

Default Rate FFEL/DL: FY2016 2.4%

FY2015 2.7%
FY2014 2.1%

Default Rate Perkins: FY2017 7.3%

FY2016 11.4%
FY2015 17%
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 4

B. Scope of Review

The U.S. Department of Education (the Department) conducted a program review at Calvin
University (Calvin) from November 18, 2019 to November 20, 2019. The review was conducted
by Ms. Mónica N. Aviña, Ms. Gwen Deurell, and Ms. Jean Brennan.

The focus of the review was to determine Calvin’s 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 Calvin’s policies and procedures
regarding institutional and student eligibility, individual student financial aid and academic files,
attendance records, student account ledgers, and consumer information requirements.

An initial sample of 15 files was identified for review from the 2018-2019 award year. The
student files were selected randomly from the list of students who 1) withdrew or ceased
attendance for any reason other than graduation; 2) were selected for verification; and 3)
received all non-passing grades (“0” GPA) for any term within the award year being reviewed.
Appendix A identifies the students whose files 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 Calvin’s specific practices and procedures must not be
construed as acceptance, approval, or endorsement of those specific practices and procedures.
Furthermore, it does not relieve Calvin of its obligation to comply with all of the statutory or
regulatory provisions governing the Title IV, HEA programs.

This report reflects initial findings. These findings are not final. The Department will issue its
final findings 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 Calvin
to bring operations of the financial aid programs into compliance with the statutes and
regulations.
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 5

Finding #1: Return of Title IV (R2T4) Calculation Errors

Noncompliance: When a recipient of Title IV grant or loan assistance withdraws from an

institution during a payment period or period of enrollment in which the recipient began
attendance, the institution must determine the amount of Title IV assistance that the student
earned as of the student’s withdrawal date. 34 C.F.R. § 668.22(a)(1).

The percentage of Title IV grant or loan assistance that has been earned by the student is equal to
the percentage of the payment period that the student completed as of the student’s withdrawal
date, if this date occurs on or before completion of 60 percent of the payment period for a
program measured in credit hours. 34 C.F.R. § 668.22(e)(2).

The unearned amount of Title IV assistance to be returned is calculated by subtracting the

amount of Title IV assistance earned by the student from the amount of Title IV aid that was
disbursed to the student as of the date of determination the student withdrew.
34 C.F.R. § 668.22(e)(4).

The institution must return the total amount of unearned Title IV assistance to be returned as
calculated; or an amount equal to the total institutional charges incurred by the student for the
payment period or period of enrollment multiplied by the percentage of Title IV grant or loan
assistance that has not been earned by the student. 34 C.F.R. § 668.22(g)(1).

“Institutional Charges” are tuition, fees, room and board (if the student contracts with the
institution for the room and board) and other educationally related expenses assessed by the
institution. 34 C.F.R. § 668.22(g)(2).

Calvin did not complete Step 5: “Amount of Unearned Title IV Aid Due From the School” of the
R2T4 calculation correctly for 8 students.

Calvin did not include institutional charges that were assessed; rather, it included components
from the student’s budget for tuition, fees, and room and board in the calculation. Also, the
institution included the budgeted room and board component for students who lived off-campus
and were not assessed room and board charges.

Student specific details are identified in the chart below:

2018-2019 Award Year

Student Semester Charges on Billing Statement Charges on R2T4 Worksheet
No. Tuition and Room and Tuition and Room and
Fees Board Fees Board
1 Spring $826.00 $5,200.00 $17,300.00 $5,200.00
4 Spring $17,300.00 $5,224.51 $17,300.00 $5,200.00
5 Spring $17,300.00 $0.00 $17,300.00 $5,200.00
7 Fall $17,300.00 $5,100.00 $17,300.00 $5,200.00
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 6

2018-2019 Award Year

Student Semester Charges on Billing Statement Charges on R2T4 Worksheet
No. Tuition and Room and Tuition and Room and
Fees Board Fees Board
Spring $17,300.00 $5,100.00 $17,300.00 $5,200.00
8 Fall $17,300.00 $1,018.46 $17,300.00 $5,200.00
9 Spring $17,300.00 $0.00 $17,300.00 $5,200.00
13 Spring $17,300.00 $5,100.00 $17,300.00 $5,200.00
14 Fall $17,300.00 $3,061.00 $17,300.00 $5,200.00

An institution’s failure to calculate correctly the return of Title IV funds and to return funds to
the appropriate Title IV programs may result in additional expense for both the Department and
the student.

Required Action: Calvin must conduct a file review of all students who withdrew during the
2018-2019 award years and perform correct R2T4 calculations.

Calvin must compile the results of the file review in a spreadsheet in both hard copy and
electronic formats. The institution must submit the file review with its response to the Program
Review Report.

The file review must be submitted in a spreadsheet in the following format:

Student Social Award Date of Aid Disbursed by Program

Name Security Year Determination Federal FSEOG Subsidized Unsubsidized PLUS
Number (DOD) Pell Grant Direct Loan Direct Loan Direct Loan
Doe, Bob XXX-XX- 2018-2019 12/11/2018 $3,048.00 $0.00 $0.00 $0.00 $0.00
XXXX
Doe, Emily XXX-XX- 2017-2018 05/16/2018 $1,480.00 $100.00 $0.00 $0.00 $0.00
XXXX

Percentage Earned Institutional Charges Unearned Percentage Amount of Title IV

Funds to be Returned
Original Revised Original Revised Original Revised Original Revised
Calculation Calculation Calculation Calculation Calculation Calculation Calculation Calculation
50% 25.9% $2,333.40 $2,333.40 50% 74.1% $1,166.70 $1,729.05
50% 23.4% $1,298.20 $1,298.20 50% 76.6% $649.10 $994.42

Original Amount Returned to the Title IV Programs Additional Funds To Be Returned to the Title IV Programs
Federal FSEOG Subsidized Unsubsidized PLUS Federal FSEOG Subsidized Unsubsidized PLUS
Pell Direct Direct Loan Direct Pell Direct Direct Loan Direct
Grant Loan Loan Grant Loan Loan
$1,166.70 $0.00 $0.00 $0.00 $0.00 $562.35 $0.00 $0.00 $0.00 $0.00
$649.10 $0.00 $0.00 $0.00 $0.00 $562.35 $0.00 $0.00 $0.00 $0.00
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 7

If Applicable, Were If Yes, Date Funds

Additional Funds Were Returned
Returned? Yes/No?
Yes 09/01/2019
No N/A

In addition, the institution must submit the following hardcopy documentation:

• All original R2T4 Calculations;

• If applicable, all revised R2T4 calculations;
• A copy of each student’s account statement;
• A copy of each student’s current academic transcript;
• Documentation of official withdrawal;
• If the student unofficially withdrew, documentation of the Last Day of Attendance
determination; and
• If additional funds were returned, documentation of the return to G5.

Finally, Calvin must review its policies and procedures to ensure they are sufficient to prevent a
recurrence of this finding. The institution must submit a copy of its revised policies and
procedures with its response to the Program Review Report.

Payment instructions for any determined liability will be provided in the Final Program Review
Determination Letter.

Finding #2: National Student Loan Data System (NSLDS) Reporting Inaccurate and/or
Late

Noncompliance: Upon receipt of an enrollment report from the Secretary, a school must update
all information included in the report and return the report to the Secretary in the manner and
format prescribed by the Secretary; and within the timeframe prescribed by the Secretary.
34 C.F.R. § 685.309(b)(1).

Unless it expects to submit its next updated enrollment report to the Secretary within the next 60
days, a school must notify the Secretary within 30 days after the date the school discovers that a
loan under Title IV of the Act was made to or on behalf of a student who was enrolled or
accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-
time basis or failed to enroll on at least a half-time basis for the period for which the loan was
intended; or a student who is enrolled at the school and who received a loan under Title IV of the
Act has changed his or her permanent address. 34 C.F.R. § 685.309(b)(2).

The Higher Education Act of 1965, as amended, (HEA) charges the Department with the
creation and maintenance of the National Student Loan Data System (NSLDS). The data
submitted by institutions is stored in NSLDS. One of its important functions is to maintain the
enrollment status of Title IV student aid recipients. The accuracy of enrollment reporting by
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 8

schools is critical for many reasons, including ensuring that the obligations and benefits that the
HEA provides for Title IV student loan recipients are respected. NSLDS enrollment information
is also used by the Department for a variety of other purposes, including tracking interest.

Calvin did not report accurate enrollment status information to NSLDS for 8 students.

For students who withdrew, the institution updated the enrollment status information to indicate
the student’s status: 1) changed from Full Time to Half Time or Less Than Half Time as of the
effective date that the student withdrew; and 2) withdrew with an effective date as of the end of
the semester.

Student specific details are identified in the chart below:

2017-2018
Student Enrollment Effective Date Enrollment Status Effective Date
No. Status Reported to NSLDS Reported to NSLDS
1 Withdrawn 01/18/2019 LTHT 02/05/2019
Withdrawn 05/16/2019
2 Withdrawn 03/29/2019 LTHT 03/29/2019
Withdrawn 05/19/2019
4 Withdrawn 11/15/2018 LTHT 11/15/2018
5 Withdrawn 4/26/2019 Half Time 04/09/2019
Withdrawn 05/16/2019
9 Withdrawn 4/25/2019 Withdrawn 05/16/2019
12 Withdrawn 04/08/2019 Withdrawn 09/19/2019
13 Withdrawn 04/10/2019 LTHT 04/10/2019
Withdrawn 05/16/2019
14 Withdrawn 10/25/2018 Withdrawn 12/18/2018

Calvin did not report enrollment status information to NSLDS timely for 7 students.

Student specific details are identified in the chart below:

2017-2018
Student Enrollment Effective Date of Cert. Date Due Date No. of
No. Status Date Determination to be Days
Reported Late
1 Withdrawn 01/18/2019 02/20/0219 09/19/2019 02/20/2019 211
2 Withdrawn 03/26/2019 03/30/2019 09/19/2019 04/29/2019 143
5 Withdrawn 04/26/2019 06/10/2019 09/19/2019 07/10/2019 71
9 Withdrawn 04/25/2019 06/10/2019 09/19/2019 07/10/2019 71
12 Withdrawn 04/08/2019 06/12/2019 09/19/2016 07/12/2019 69
13 Withdrawn 04/08/2019 04/12/2019 09/19/2019 05/12/2019 130
Calvin University
OPE ID: 00224100
PRCN: 202010330103
Page 9

2017-2018
Student Enrollment Effective Date of Cert. Date Due Date No. of
No. Status Date Determination to be Days
Reported Late
14 Withdrawn 10/25/2018 01/30/2019 02/06/2019 11/24/2018 74

Accurate enrollment information is a vital component of the Federal Student Loan Programs.
The information reported to NSLDS determines if the student is still considered in school, must
be moved into repayment, or is eligible for an in-school deferment. For students moving into
repayment, the out-of-school effective date determines when the grace period begins and how
soon a student must begin repaying loan funds.

Required Action: Calvin must conduct a file review of all students who participated in the Title
IV programs and who were enrolled in the 2018-2019 award years to determine that: 1) the
enrollment status information was reported accurately to NSLDS during the 2018-2019 award
year; and, 2) if necessary, to update the most current enrollment status information to accurately
reflect the correct enrollment status.

In its file review, Calvin must review both the Campus Level and Program Level enrollment
status information reported for each student.

Calvin must compile the results of the file review in a spreadsheet in both hard copy and
electronic formats. The institution must submit the file review with its response to the Program
Review Report.

The file review must be submitted in a spreadsheet in the following format:

Student Social Current Current Enrollment Enrollment Certified

Name Security Enrollment Enrollment Status Status Date
Number Status Status Reported Effective
Effective to NSLDS Date
Date Reported
to NSLDS
Doe, XXX- FT 01/20/2019 FT 01/20/2019 01/22/2019
Jane XX-
XXXX
Doe, XXX- Withdrawn 02/23/2019 Withdrawn 02/23/2019 05/15/2019
John XX-
XXXX
Doe, XXX- Withdrawn 10/12/2018 FT 01/12/2019 01/14/2019
Sally XX-
XXXX
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Enrollment Status If No, Campus Level If No, Program Level Reported If No, Number
Reported Correctly? Enrollment Updated Enrollment Updated with Timely? Yes or of Days Late
Yes or No with NSLDS? Yes or NSLDS? Yes or No No
No
Yes N/A N/A Yes N/A
Yes N/A N/A No 25
No Yes Yes Yes N/A

Calvin must review its policies and procedures to ensure they are sufficient to prevent a
recurrence of this finding. The institution must submit a copy of its revised policies and
procedures with its response to the Program Review Report.

Finding #3: Failure to Return Unclaimed Title IV Funds

Noncompliance: A Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA
program funds credited to a student’s ledger account for a payment period exceeds the amount
assessed the student for allowable charges associated with that payment period. A Title IV, HEA
credit balance must be paid directly to the student or parent as soon as possible, but no later than
fourteen (14) days after the balance occurred if the credit balance occurred after the first day of
class of a payment period; or fourteen (14) days after the first day of class of a payment period if
the credit balance occurred on or before the first day of class of that payment period.
34 C.F.R. § 668.164(h).

Notwithstanding any State law (such as a law that allows funds to escheat to the State), an
institution must return to the Secretary, lender, or guaranty agency, any Title IV, HEA program
funds, except FWS program funds, that it attempts to disburse directly to a student or that are not
received by the student or parent. For FWS program funds, the institution is required to return
only the Federal portion of the payroll disbursement. 34 C.F.R. § 668.164(l)(1).

If an EFT to a student’s or parent’s financial account is rejected, or a check to a student or parent

is returned, the institution may make additional attempts to disburse the funds, provided that
those attempts are made no later than 45 days after the EFT was rejected or the check returned.
In cases where the institution does not make another attempt, the funds must be returned to the
Secretary before the end of this 45-day period. 34 C.F.R. § 668.164(l)(2).

If a check sent to a student or parent is not returned to the institution but is not cashed, the
institution must return the funds to the Secretary no later than 240 days after the date it issued the
check. 34 C.F.R. § 668.164(l)(3).

Calvin’s policy for the return of unclaimed Title IV credit balance funds was inadequate.

Calvin’s policy did not contain a provision to return unclaimed Title IV credit balance funds to
the Department within 240 days.
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Calvin’s failure to monitor outstanding credit balance checks may create a financial burden for
the student and the Department.

Required Action: During the on-site visit, Calvin provided the Department a spreadsheet that
identified 35 students with unclaimed credit balance checks. Subsequent to the on-site visit, the
institution provided the Department with billing statements for these students. The Department
reviewed the billing statements and did not identify any students whose unclaimed checks were
Title IV credit balances.

Also, Calvin provided the Department with its updated policies and procedures. The updated
policies and procedures should ensure that unclaimed Title IV credit balances are returned to the
appropriate Title IV program on the student’s behalf within 240 days.

The Department will not require any additional information at this time; however, the institution
may provide any additional information it would like the Department to consider prior to issuing
a final determination.

Finding #4: Improper Origination

Loan Period Not Equal to Period of Enrollment

Noncompliance: A school participating in the Federal Direct Loan Program must ensure that
any information it provides to the Secretary in connection with loan origination is complete and
accurate. 34 C.F.R. § 685.301(a)(1).

The period of enrollment is the period for which a Federal Direct Subsidized, Federal Direct
Unsubsidized or Federal Direct Plus loan is intended. The period of enrollment must coincide
with one or more bona fide academic terms established by the school for which institutional
charges are generally assessed (e.g., a semester, trimester, or quarter in weeks of instructional
time; an academic year; or the length of the program of study in weeks of instructional time).
The period of enrollment is also referred to as the loan period. 34 C.F.R. § 685.102(b).

Calvin originated William D. Ford Federal Direct Loans (Direct Loan) with a loan period that
did not agree with the institution’s established period of enrollment for two students.

The academic periods of enrollment established by the institution for the 2018-2019 award year
was:
Full Year: September 4, 2018 to May 16, 2019
Fall Only: September 4, 2018 to December 18, 2018
Spring Only: January 3, 2019 to May 16, 2019

Student specific details are as follows:

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Student #1: Calvin disbursed $1,732.00 in Subsidized Direct Loan funds and $2,969.00
in Unsubsidized Direct Loan funds to the student’s account on December 11, 2018. The
student withdrew from the institution on January 18, 2019.

Common Origination and Disbursement (COD) records indicate that the Direct Loan
period was October 1, 2018 to January 28, 2019, which does not agree with the
established period of enrollment of September 4, 2018 to December 18, 2018.

Student #14: Calvin disbursed $1,608.00 in Subsidized Direct Loan funds to the
student’s account on September 20, 2018. The student withdrew from the institution on
October 25, 2018.

COD records indicate that the Direct Loan period was September 4, 2018 to January 28,
2019, which does not agree with the established period of enrollment of September 4,
2018 to December 18, 2018.

Failure to report accurate loan origination information may cause a student to receive Title IV
loan funds in excess of their eligibility and create a financial burden to the Department.

Required Action: Subsequent to the on-site visit, Calvin submitted the Department a
spreadsheet which identified 95 students whose loan periods did not agree with the period of
enrollment. Student specific details may be found in Appendix B: Finding #4 Student List.

For the students identified in Appendix B, Calvin must correct the loan period dates to match the
period of enrollment and provide documentation confirming that the loan period was updated
with its response to the Program Review Report.

Calvin must review its policies and procedures to ensure they are sufficient to prevent a
recurrence of this finding. The institution must submit a copy of its revised policies and
procedures with its response to the Program Review Report.

Finding #5: Inaccurate Common Origination and Disbursement Reporting

Noncompliance: An institution makes a disbursement of Title IV, HEA program funds on the
date that the institution credits a student’s account at the institution or pays a student or parent
directly with funds received from the Secretary. 34 C.F.R. § 668.164(a)(1).

The Secretary accepts a student's Payment Data that is submitted in accordance with procedures
established through publication in the Federal Register, and that contains information the
Secretary considers to be accurate in light of other available information including that
previously provided by the student and the institution. 34 C.F.R § 686.37(b).
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For Federal Pell Grant and Federal Direct Loan Program disbursements and adjustments made
on or after April 1, 2013, the deadline for reporting to COD was reduced from 30 days to 15
days. Federal Register (February 28, 2013), Volume 78, Number 40, Pages 13651 to 13656.

Calvin did not report accurate disbursement information to COD for one student during the
2018-2019 award year.

Student specific details is as follows:

Student #9: Calvin disbursed $1,732.00 in Subsidized Direct Loan funds and $990.00 in
Unsubsidized Direct Loan funds to the student’s account on October 18, 2018. The
institution reported the disbursement dates to COD as October 2, 2018.

An institution’s failure to report accurate disbursement dates to COD may result in increased
interest costs for the Department and the student.

Required Action: Calvin must adjust the COD disbursement records for Student #9 to reflect
the correct disbursement date for the Subsidized and Unsubsidized Direct Loan funds of October
18, 2018.

Calvin must review its policies and procedures to ensure they are sufficient to prevent a
recurrence of this finding. The institution must submit a copy of its revised policies and
procedures with its response to the Program Review Report.

Finding #6: Title IV Credit Balance Policy Inadequate/

Failure to Have a Written Authorization to Hold a Title IV Credit Balance

Noncompliance: An institution may credit a student’s ledger account with Title IV, HEA
program funds to pay for allowable charges associated with the current payment period.
34 C.F.R. § 668.164(c)(1).

If an institution obtains written authorization from a student or parent, the institution may use the
student’s or parent’s Title IV HEA program funds to pay for charges that are included in that
authorization; and, unless the Secretary provides funds to the institution under the reimbursement
payment method or the heightened cash monitoring payment method respectively, hold on behalf
of the student or parent any Title IV, HEA program funds that would otherwise be paid directly
to the student or parent as a credit balance. 34 C.F.R. § 668.165(b)(1).

In obtaining the student’s or parent’s authorization to perform an activity described in paragraph

(b)(1), an institution:

• May not require or coerce the student or parent to provide that authorization;
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• 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. § 668.165(b)(2).

A student or parent may authorize an institution to carry out the activities described in paragraph
(b)(1) for the period during which the student is enrolled at the institution.
34 C.F.R. § 668.165(b)(3).

If a student or parent modifies an authorization,

• The modification takes effect on the date the institution receives the modification notice;

• If a student or parent cancels an authorization to use Title IV, HEA program funds to pay
for authorized charges, the institution may use Title IV, HEA program funds to pay only
those authorized charges incurred by the student before the institution received the notice;
and

• If a student or parent cancels an authorization hold Title IV, HEA program funds, the
institution must pay those funds directly to the student or parent as soon as possible but
no later than 14 days after the institution received that notice. 34 C.F.R. § 668.165(b)(4).

If an institution holds excess student funds, the institution must

• Identify the amount of funds the institution holds for each student or parent in a
subsidiary ledger account designed for that purpose;

• Maintain, at all times, cash in its depositor account in an amount at least equal to the
amount of funds the institution holds on behalf of the student or the parent; and

• Notwithstanding any authorization obtained by the institution, pay any remaining balance
on loan funds by the end of the loan period and any remaining other Title IV, HEA
program funds by the end of the last payment period in the award year for which they
were awarded. 34 C.F.R. § 668.165(b)(5).

Calvin’s Credit Balance Policy was inadequate.

Calvin allowed students or parents to request a credit balance to be held but did not include
information concerning this request (whether a Title IV Credit Balance or a Non-Title IV Credit
Balance) in its policies and procedures.

An institution’s failure to have a policy concerning Title IV credit balances may deprive a
student or parent of using the Title IV credit balance to be held for future charges and may cause
the institution to carry excess cash.
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Required Action: Calvin must update its credit balance policies and procedures to include the
regulatory information pertaining to Title IV credit balances identified above. The institution
must also develop a written Authorization to Hold form for student or parents to submit when
requesting that a Title IV credit balance be held.

The institution must submit a copy of its revised policies and procedures, as well as the
Authorization to Hold form with its response to the Program Review Report.

Finding #7: Failure to Notify Students of Availability of Consumer Information

Consumer Information Inadequate

Noncompliance: An institution annually must distribute to all enrolled students a notice of the
availability of the information required to be disclosed. The notice must list and briefly describe
the information and tell the student how to obtain the information. 34 C.F.R. § 668.41(c)(1).

An institution that discloses information to enrolled students by posting the information on an

Internet website or an Intranet website must include in the notice the exact electronic address at
which the information is posted and a statement that the institution will provide a paper copy of
the information on request. 34 C.F.R. § 668.41(c)(2).

Institutional information that the institution must make readily available to enrolled and
prospective students includes, among other things, a statement that a student’s enrollment in a
program of study abroad approved for credit by the home institution may be considered
enrollment at the home institution for the purposes of applying for assistance under the Title IV,
HEA programs. 34 C.F.R. § 668.43(a).

An institution that enters into an agreement with a potential student, student or parent of a
student regarding a Title IV HEA loan is required to inform the student or parent that the loan
will be submitted to the National Student Loan Data System (NSLDS) and will be accessible by
guarantee agencies, lenders, and institutions determined to be authorized users of the data
system. HEA Sec. 485B(d)(4).

Calvin did not deliver an annual notification to students of the availability of its consumer
information.

Calvin’s consumer information does not contain all required elements as set forth in federal
regulations. The institution’s consumer information does not include:

• A statement that a student’s enrollment in a program of study abroad approved for credit
by the home institution may be considered enrollment at the home institution for the
purposes of applying for assistance under the Title IV, HEA programs; and
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• A notice that Direct loan information will be submitted to the National Student Loan Data
System (NSLDS) and will be accessible by guarantee agencies, lenders, and institutions
determined to be authorized users of the data system.

An institution’s failure to provide complete consumer information leaves students uninformed of

their rights and responsibilities for participation in the Title IV programs.

Required Action: Calvin must update its consumer information to include the regulatory
elements identified above. The institution must submit a copy of its revised consumer
information with its response to the Program Review Report.

Once the Department has reviewed the updated consumer information submitted with the
institution’s written response, Calvin must then notify students of the availability of consumer
information on the institution’s website and include that a paper copy of the information would
be provided upon request. The institution must submit documentation that the students were
notified of its updated consumer availability at that time.

Finding #8: Federal Funds Not Identified in Depository Account Title

Noncompliance: For each depository account that includes Title IV, HEA program funds, an
institution located in a State must clearly identify that Title I, HEA program funds are maintained
in that account by

• Including in the name of each depository account the phrase, “Federal Funds”; or
• Notifying the depository institution that the depository account contains Title IV, HEA
program funds that are held in trust and retaining a record of that notice; and (except for a
public institution located in a State or a foreign institution) filing with the appropriate
State or municipal government entity a UCC-1 statement disclosing that the depository
account contains federal funds and maintaining a copy of that statement.
34 C.F.R. § 668.163(a)(2).

Calvin did not identify that its bank account included Title IV, HEA program funds. The
institution’s bank account title does not contain the phrase “Federal Funds” as required by
federal regulations.

An institution’s failure to clearly identify Title IV funds may increase the risk for the misuse of
federal funds.

Required Action: Subsequent to the on-site visit, Calvin provided adequate documentation to
the Department that its depository account now contains the phrase, “Federal Funds” in the bank
account title.
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The Department will not require any additional information at this time; however, the institution
may provide any additional information it would like the Department to consider prior to issuing
a final determination.

D. Appendix A

Appendix A (Student Sample) contains personally identifiable information and will be emailed
to Calvin as an encrypted WinZip file using Advanced Encryption Standard, 256-bit. The
Department will send the password needed to open the encrypted WinZip file(s) in a separate email.

Appendix B is attached to this report.