West Virginia’s Public Colleges recently made the news when the Department placed more than a dozen schools in the state on Heightened Cash Monitoring after the schools failed to provide their audit on time. It’s extremely rare to see a public school placed on Heightened Cash Monitoring since public schools are backed by the “full credit and faith of the state” but the Department cited the State’s colleges for their demonstrated lack of administrative capability over the late and missing audits. So let’s look at the ten reasons a school gets placed on HCM.


Accreditation Problems – Includes accreditation actions such as the school’s accreditation has been revoked and is under appeal, or the school has been placed on probation.

Administrative Capability – Concerns about the institution’s ability to manage the Title IV programs including student file maintenance, record retention, and verification. 

Audit Late/Missing – School did not submit their audit by the due date and is considered not financially responsible.

Audit (Severe Problems) – School has severe audit findings which could include financial statements, internal controls, and compliance with laws, regulations, and provisions of contract or grant agreements.

Default Rate – A school’s cohort default rate for Perkins loans made to students for attendance at the school exceeds 15% or the cohort default rate for Federal Stafford loans or for Direct Subsidized/Unsubsidized Loans made to students for attendance at the school equals or exceeds 30% for the three most recent fiscal years or if the most recent cohort default rate is greater than 40%.

Denied Recertification (PPA Not Expired) – School’s recertification was denied but its Program Participation Agreement has not yet expired.

Financial Responsibility – School has a failing or a zone composite score or other concerns such as unreconciled accounts.

Change In Ownership Problems (Eligibility) – Issues identified with information needed on a Change in Ownership application such as missing/incorrect same-day balance sheet or other needed documentation; or an unreported CIO is discovered.

Program Review – School is being reviewed by the Department as part of its normal oversight and monitoring responsibilities or as a result of concerns regarding the school’s administrative capability and financial responsibility.

Program Review (Severe Findings) – School has potential of severe program review findings such as failure to make refunds or return of Title IV funds.



If your school is applying to participate in the Title IV federal student aid programs for the first time, or is undergoing a change of ownership your school Owner/President/CEO and Financial Aid Administrator must attend one of the Department’s “Fundamentals of Federal Student Aid” training workshops.

For new schools, attendance at this workshop is required to complete your institution’s certification and is one of the prerequisites for coming off of “provisional status”, which usually occurs 12-24 months after your school is initially approved for Title IV funding. When your school applies for recertification, the Department will check to make sure that both of the required people have attended the workshop, and for the appropriate number of days. The Department may also request that you send a copy of the certificate that you received, to prove your attendance.

If your school is undergoing a change Change of Ownership, you must also attend this workshop within 12 months.

The Department recently announced the dates and locations of each workshop that will be offered from July 2017 through June 2018. Each in-person workshop is four and one-half days in length and is conducted at one of the Department of Education’s regional training facilities. Fundamentals trainings events fill up very quickly. So if you need to attend, be sure to register as soon as possible in order to secure your seat for a time and location that is convenient.

Anyone wishing to attend the in-person, four and one-half day workshop, Fundamentals of Federal Student Aid Administration, must first successfully complete the online, self-paced tutorial, Introduction to Federal Student Aid. The online tutorial may take up to 20 hours to complete, so plan ahead so that you can register for the in-person workshop you want to attend.

For more information refer to DCL ID: ANN-17-03.