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 Secretary of Education.)

   X   Compliance                    ___Partial Compliance                       ___Non-Compliance

Narrative

St. Petersburg College is in compliance with this federal requirement regarding its program responsibilities under the Title IV of 1998 Higher Education Amendments.

The College received the Program Participation Agreement from the US Department of Education that enables the College to receive and award Title IV Financial Aid program funds.  Title IV Financial Aid Programs consists of the Federal Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work-Study Program (FWS), Federal Parent Loan for Undergraduate Students (PLUS), Federal Subsidized Stafford Loan, and the Federal Unsubsidized Stafford Loan.  The Eligibility and Certification Approval Report confirms SPC’s ability to award Title IV financial aid to students enrolled in all Associate Degree programs, selected Bachelor Degree programs and college credit certificate programs.  The College’s Program Participation Agreement and Eligibility and Certification Approval are effective through June 30, 2008.

Issues with Title IV Programs

The College does not have any issues affecting the status of our Title IV programs.

 SPC remains committed to upholding high standards in the administration of student financial aid services.  SPC’s Office of Scholarships and Student Financial Assistance offer a broad range of services.  The following table depicts the percentage of students receiving financial assistance for the Academic Year 2005-2006 Credit Classes (numbers are approximate).

Percentage of Students Receiving Financial Assistance, 2005-2006

Historically, the College has awarded financial aid to 45-50% of students.  The amounts and types of financial assistance that a student receives are determined through federal, State and institutional guidelines and are offered to students in combinations or "packages" which may consist of grants, scholarships, loans and employment designed to help students meet educational expenses.  Grants and scholarships are regarded as "gift" assistance and need not be repaid, although they may carry certain provisions to which one must adhere.  Loans are usually offered at low interest rates and can be repaid over an extended period of time.  Where assistance is offered in the form of a job, the student is paid an hourly rate for work performed.

The mission of the office of Scholarships and Student Financial Assistance (SSFA) is to assist students in securing the funds necessary to pursue their goals at St. Petersburg College.  The office is committed to providing quality service, reliable consumer information and access to information on scholarships and student financial assistance.  In addition, staff members are committed to working with the community by providing financial assistance awareness workshops and consultation for high school counselors and other members of the public.

Reimbursement Method

The College has not been placed on the reimbursement method.

As a result of SPC meeting the responsibility for proper administration of federal funds, the College is noted as a Just-In-Time Institution for the Federal Pell Grant program with USDOE.  In addition, St. Petersburg College receives advance funding for Federal Campus-Based Programs, which consist of the Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study (FWS).  The SPC Scholarships and Student Financial Assistance Office files the FISAP (Fiscal Operations Report and Application to Participate), which is due the last working day of September of each year.  The completion and filing of the FISAP is a USDOE requirement for schools to continue receiving Title IV funding.  The following table depicts the federal financial assistance participation in Title IV programs for 2005-2006.

 Federal financial assistance participation in Title IV programs, 2005-2006

Type of Financial Assistance	2005-2006             Award Amount	Number of                    Recipients Awarded
Federal Pell Grant	$17,945,043	8636 Awards
Federal Family Education Loan: Stafford (Sub/Unsubsidized) & PLUS	$33,870,280	11096 Awards
Federal SEOG	$     403,694	1362 Awards
Federal Work Study (FWS)	$      648,547	256 Awards

Letter of Credit

The College has not been required to obtain a letter of credit.

Complaints Filed with the Department of Education

There have not been any complaints filed with the Department of Education.  St. Petersburg College follows the federal regulations set by U.S. Title IV Student Aid Programs.

In addition, SFC complies with the responsibility for disseminating financial aid and consumer information to students.  Examples of the sources for providing this information to students are as follows:

Sources of information for students

SPC Catalog 2006-2007	Academic Calendar on pages  5-6, Scholarships & Student Financial Assistance on pages 60-77
SPC Course Schedule Booklet	2006-2007 Financial Assistance Checklist (Introduction)
SPC Financial Aid Web site	St. Petersburg College ::: Scholarships and Student Financial Assistance
SPC Student Planner and Handbook 2006-2007	Scholarships & Student Financial Assistance, Policies and Procedures Affecting Students:  More about Registration on pages 173-178, Students Rights & Responsibilities on pages 208-222
SSFA Web site Forms	Forms 2006-2007

Independent Audits of the Institution’s Financial Aid Programs

St. Petersburg College’s financial awards programs are audited annually by the State of Florida Auditor General Office, in accordance with the U. S. Office of Management and Budget Circular A-133.  As an early auditee in the annual audit cycle, St. Petersburg College often is subjected to the new emphases within the State Audit process, most recently in reviewing the institution’s attendance monitoring process used to determine return of federal financial funds.  SPC corrects findings with energy and integrity and believes its new attendance monitoring procedures can be used as a model for other institutions.  The most recent report, 2005-2006 Financial Award Audit included four findings; this Audit Report will be published no later than 03/31/07.  There were five findings in the 2004-2005 Financial Award Audit and three findings for fiscal year 2003-2004.  The College received no findings in Federal Audits for 2001-2002 and 2002-2003.  The College’s responses to the audit recommendations and procedural enhancements for Fiscal Year 2005-2006 are as follows:

• Finding FA 06-102 (official withdrawal) pertains to the return of Title IV (R2T4) funds.  For standard term students the College did not have adequate procedures to timely return all unearned funds to the Title IV programs and lenders.  Also, the College did not have procedures to correctly calculate return of Title IV funds for students enrolled entirely in non-standard term courses; nor a procedure to obtain required student confirmations for students that withdrew from a module when enrolled in two sequential modules in a non-standard term.

• Response:  The College is absolutely committed to continuous improvement of the management and control over the Federal aid funds provided for our students.  The College has developed procedures, including system changes as applicable, to ensure the timely calculation and return of Title IV funds.  For example, effective Fall term 2006, Faculty are required to take attendance in the Learning Management System.  Program Directors are providing oversight to insure that the attendance is posted and that withdrawals are performed on a timely basis in the separate Student Administration System.  The College has implemented a separate R2T4 date for the non-standard term courses and is accurately calculating the return of Title IV for students who are enrolling only in non-standard term classes.  The estimated corrective action date is October 24, 2006.

• FA 06-103 (unofficial withdrawals) pertains to the return of Title IV funds.  The College had not implemented adequate procedures to determine whether Title IV funds were earned for students enrolled in standard or non-standard terms.  As a result, the College did not always timely return unearned Title IV HEA funds to the applicable lenders for those students who unofficially withdrew prior to the 60 percent point of the payment period.

• Response:  The College continues its commitment to compliance to the highest audit standards and requirements.  An additional $600,000 has been dedicated to increasing financial aid staffing. Effective Fall term 2006, the College has synchronized its academic and R2T4 withdrawal dates.  The new WF grade is now available to indicate the following:  1) a withdrawal by a student who is attempting to complete a course for the third or subsequent attempt or 2) a grade given by an instructor to a student after the last date to withdraw has passed and the student’s attendance has ceased prior to the end of the term.  The W and WF grades enable the Registrar to identify, through weekly system reports any student who has unofficially withdrawn.  Term withdrawal is then completed and, if applicable, R2T4 is calculated.  Estimated Corrective Action Date is October 24, 2006.
• Finding FA 06-100 pertains to the disbursement of FFEL funds by electronic funds transfer (EFT) to students’ accounts.  The College did not have procedures in place to notify and provide all required information, in writing or electronically, to student or parent FFEL loan borrowers within 30 days before or after crediting a student’s account with FFEL funds.  The College implemented electronic notification procedures of all required data utilizing the Collegewide Student email system for all new loans disbursed effective March 13, 2006.  For 30 students tested, 23 received FFEL loans for which notifications were required.  Of the 23 students, 21 had loans disbursed prior to March 13, 2006, for which students’ notifications were not done; however, for the 2 students that had loans disbursed on or after March 13, 2006, the required notice was provided.

• Response:  The College implemented an electronic notification of all required data utilizing the Collegewide student email system in March, 2006. Studies were conducted to determine the effectiveness of using student email notifications; results indicated that students underutilized this service.  Even though the College is in compliance by electronically notifying the students, we are currently developing a process to incorporate both email and hard copy, through the postal service, notification of this data to enhance communication to the student.

• Finding FA 06-105 pertains to the timely report changes in FFEL student loan borrowers’ enrollment status.  Due to programming errors (finding FA 05-105), enrollment data submitted to SNLDS did not accurately reflect the enrollment status changes of the FFEL student loan borrowers.  These programming errors remained uncorrected for most of the 2005-06 fiscal year. However, on June 28, 2006, the College corrected the programming errors noted in the prior audit and submitted to NSC the final Fall 2005 and Spring 2006 file changes.  The test of 20 FFEL student loan borrowers who withdrew from the institution during the Fall 2005 or Spring 2006 terms disclosed that the enrollment status changes submitted to NSC on June 28, 2006, agreed with the College’s records.  However, these enrollment status changes were not timely reported to NSLDS for 10 of the students.

• Response:  Programming changes were made in June 2006 to report the correct enrollment status change date when the student is term withdrawn.  The College’s Office of Scholarships & Financial Assistance changed the NSLDS calendar to request data from the NSLDS on the first of every month.  Prior to this change, there was a 2-3 month gap in requests from NSLDS to NSLC during the summer months.  Also, the College Registrar’s Office is in the process of getting access to the NSLDS system so they can monitor the timely notification of the transmissions from the National Student Clearinghouse.  Estimated Corrective Action Date is September 26, 2006.

The SSFA department is committed to continuous improvement of the management and control over the financial funds provided to our students.  The department has evaluated and developed new procedures, including the R2T4 process to insure timely notification of R2T4.  A new full-time position was created to handle the R2T4 process full time for the SSFA department.  This new position processes weekly R2T4 reports after the term withdrawal reports are provided by the College Registrar to assure the timely notification to the Department of Education and students.  Also, a procedures/operational manual for R2T4 was created to ensure college procedures were being followed.  The department continues to evaluate policies and procedures to ensure compliance in all areas of the department.

Significant Impending Litigation Issues.  The College is not involved in any significant impending litigation issues.

Significant Unpaid Dollar Amounts Due Back to the U.S. Department of Education.  There are not significant unpaid dollar amounts due back to the U.S. Department of Education.

Adverse Communication Been Received from the U.S. Department of Education.  SPC has not had any adverse communications that will affect our ability to participate in the Title IV Financial Aid Programs.

Institution’s Student Loan Default Rate.   St. Petersburg College continuously monitors the quality of the administration and delivery of student aid.  The cohort rate is the percentage of a school’s student borrowers who enter repayment on student loans during a particular federal fiscal year, October 1 to September 30, and default in that fiscal year or the next fiscal year.  Our 2001 Cohort Default Rate was at 8.8, which we were able to reduce to 5.3 for our 2002 rate, 5.9 for our 2003 rate and 6.8 for our 2004 rate.  The 2004 Florida Community Colleges Cohort Default Rates ranged from 3.2% to 12.8% for an average of 8.4%; SPC’s rate is the fourth lowest of the 26 community colleges.  We attribute our success in lowering default rates to a number of ongoing improvements:

·         A new and improved Steering to Success, A Practical Guide to Financial Assistance brochure which offers step by step directions to students; this guide is available as a printed document, and has been parsed into various areas on the College’s Scholarships and Student Financial Assistance Web site.

·         Continued and expanded specific conditions of financial assistance awards listed on the SSFA Web page.

·         An explicit and enforced withdrawal policy.

Infractions to Regulations Which Would Jeopardize Title IV Funding

The College is not aware of infractions to regulations which might jeopardize Title IV funding.