United states department of education office of inspector general




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UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF INSPECTOR GENERAL
501 I STREET, SUITE 9-200

SACRAMENTO, CALIFORNIA 95814


PHONE (916) 930-2388 • FAX (916) 930-2390


August 24, 2005

Control Number

ED-OIG/A09E0015

Mr. Todd S. Nelson

President and CEO

Apollo Group, Inc.

4615 East Elwood Street

Phoenix, AZ 85040


Dear Mr. Nelson:
This Final Audit Report, entitled University of Phoenix’s Processing of Student Financial Aid Disbursements for the Higher Education Act, Title IV Programs, presents the results of our audit. The purpose of the audit was to determine whether the University of Phoenix (UOP) has policies and procedures that provide reasonable assurance that the institution properly makes initial and subsequent disbursements to students enrolled in Title IV eligible programs. Our review generally covered disbursements to UOP students who received Title IV funds during the period September 1, 2002 through March 31, 2004. The Objective, Scope, and Methodology section of this report further explains the extent of audit coverage for each aspect of our review.

BACKGROUND
UOP, a wholly-owned subsidiary of the Apollo Group, Inc. (Apollo), is a private, for-profit institution of higher education offering associate, bachelor, master, and doctoral degrees and professional certificate programs. UOP has 55 campuses and 102 learning centers located in 33 states, Puerto Rico, and Vancouver, British Columbia. Its educational programs are also offered worldwide via the Internet through University of Phoenix Online, a division of UOP. Apollo contracts with Affiliated Computer Services, Inc. (ACS), a third-party servicer, for the processing of financial aid for UOP’s students. UOP is accredited by the Higher Learning Commission of the North Central Association of Colleges and Schools.
UOP uses a non-term academic calendar and measures the length of its educational programs in credit hours. Students, including students at UOP Online, generally enroll in an educational program that encompasses a series of five to six-week courses. Typically, the courses are taken one at a time, sequentially, over the length of the program.

UOP is a participant in the U.S. Department of Education’s Distance Education Demonstration Program and participates in the Higher Education Act (HEA), Title IV Programs listed in the below table.





Title IV Funds Reported in Annual Audit Reports

Title IV Program

Students (a)

Title IV Funds

2003

2004

2003

2004

Federal Family Education Loan Program (FFEL)

107,203

161,781

$778,026,809

$1,599,370,890

Federal Pell Grant Program (Pell Grant)

27,908

50,939

60,920,063

142,434,388

Federal Supplemental Educational Opportunity Grant Program (FSEOG)

3,393

7,381

1,173,602

2,311,921

Federal Perkins Loan Program

225

255

629,439

511,349

Total Title IV Funds




$840,749,913

$1,744,628,548

(a) Students may have received funds from more than one Title IV program.

UOP primarily uses three electronic interactive Apollo systems in processing student financial aid: the Student Record, Financial Aid, and Accounting systems.1



AUDIT RESULTS
Except for two areas, we concluded that UOP had policies and procedures that provide reasonable assurance that the institution properly makes initial and subsequent disbursements to students enrolled in Title IV eligible programs. We found that UOP used an automated process for checking eligibility prior to making Title IV disbursements that placed a hold on disbursements that failed the eligibility checks. We also found that the staff who reviewed disbursements that failed the eligibility checks generally made proper decisions regarding student eligibility for released disbursements. However, UOP’s policies and procedures did not ensure that 1) Title IV disbursements were credited to student accounts for only allowable institutional charges and 2) students who received Title IV disbursements were enrolled in eligible programs.
Our conclusion on the adequacy of UOP’s policies and procedures is based on 1) our understanding of the system of internal control that existed during the audit period for making the initial and second Title IV disbursements in an academic year and 2) our evaluations and limited tests of selected data elements in Apollo’s systems that were related to determining student eligibility for the second disbursement. The projection of this evaluation of the system of internal control to future periods is subject to the risk that procedures may become inadequate because of changes in conditions, or that the degree of compliance with the procedures may deteriorate.
UOP did not concur with our finding and recommendations concerning UOP’s policies and procedures for crediting Title IV disbursements to student accounts for institutional charges. UOP concurred with the other finding and recommendations presented in the report. The text of UOP’s comments is included as an attachment to the report.

FINDING NO. 1 – UOP Improperly Used Title IV Funds to Credit Student Accounts for Prior Learning Assessment Fees

Of the 197,230 students who received Title IV funds during the period September 1, 2002 through March 31, 2004, we identified 834 students for whom UOP had improperly used $319,338 in Title IV funds to credit the student accounts for prior learning assessment fees.


UOP students may petition for an assessment of prior learning to meet the completion requirements for their educational program. A student may earn up to 30 prior learning credits for professional training (workshops, seminars, licenses, business and professional courses, and other institutionally-sponsored course work) and undergraduate students may earn up to 30 additional credits for verified college-level learning gained through experience (experiential learning).2
To initiate the assessment process, the student takes the following action—


  • Professional training. The student submits a completed Professional Training Portfolio to UOP’s Prior Learning Assessment Center (Center).

  • Experiential learning. The student enrolls in either UOP’s Experiential Learning course (GEN/110) or UOP’s Experiential Learning Essay Tutorial. The instruction provided helps students prepare the experiential course writing that will be evaluated for credit.

Then, the Center evaluates the student’s prior learning and awards academic credit, which is posted in the student’s academic transcript.


UOP’s school catalog for 2003-2004 states that the tuition for GEN/110 is based on the prevailing tuition rate for the major course work and that students will earn one credit upon successful completion of the course. The catalog contains the following information on assessment fees charged for the Center’s services—
When materials are complete, they are sent to the Prior Learning Assessment Center in Phoenix and a $90 submission fee is collected. The following evaluation and posting fees apply to credit awarded through Prior Learning Assessment—


  • $30.00 per credit for standardized evaluations, and items from the Apollo Quick ListTM.

  • $55.00 per credit for professional course work and training, and experiential learning essays.

  • Costs per credit for articulated course work and training may vary.

UOP’s fees for the evaluation and posting of credits awarded for prior learning are separate from tuition and fees related to the student’s educational program. Specifically, the catalog states—


Charges arising out of [assessment] services and the posting of credit awarded for prior learning are not included as part of the major curriculum fees and tuition.
Use of Title IV funds to pay the tuition cost for the GEN/110 course is appropriate since the course instruction was provided by UOP and the credit received for completing the course may be used to meet the minimum credits for completion of the student’s educational program. However, the materials submission fee and the fees for evaluation and posting of credit for prior learning are not institutional charges that can be paid with Title IV funds. These charges are not incurred by the student at the institution for educationally related activities delivered by the institution during the academic year or loan period. Thus, UOP should not have applied Title IV funds to student accounts for the fees.
The regulations at 34 C.F.R. § 668.164(d) state—
Crediting a student's account at the institution. (1) Without obtaining the student's or parent's authorization under Sec. 668.165, an institution may use title IV, HEA program funds to credit a student's account at the institution to satisfy current charges for--

(i) Tuition and fees;

(ii) Board, if the student contracts with the institution for board; and

(iii) Room, if the student contracts with the institution for room.

(2) After obtaining the appropriate authorization from a student or parent under Sec. 668.165, the institution may use title IV, HEA program funds to credit a student's account at the institution to satisfy--

(i) Current charges that are in addition to the charges described in paragraph (d)(1) of this section that were incurred by the student at the institution for educationally related activities;

* * * * *

(4) For purposes of this paragraph, current charges refers to charges assessed the student by the institution for--

(i) The current award year; or

(ii) The loan period for which an institution certified or originated a loan under the FFEL or Direct Loan programs.


The HEA § 472 defines the term “cost of attendance” for Title IV purposes. The definition includes the following explanation of “tuitions and fees”—
[T]uition and fees normally assessed a student carrying the same academic workload as determined by the institution . . . .
The fees for the evaluation and posting of credits awarded for prior learning are not included in the tuition and fees portion of the student’s cost of attendance. The fees are not normally assessed to students as part of their academic workload since the fees are only incurred if the student submits materials for assessment and the Center awards credits to the student. Only 834 of the 197,230 students in our audit universe were assessed prior learning fees, which were paid with Title IV funds. UOP acknowledged in its school catalog that the fees were not part of the tuition and fees for the student’s educational program (i.e., not included as part of the major curriculum fees and tuition). In addition, the fees were incurred by the student for the evaluation of activities that occurred at locations other than UOP and that may have taken place prior to the student’s enrollment. Thus, the fees were not charges that were incurred by the student at the institution for educationally related activities.
UOP’s written policies included prior learning assessment fees as an allowable use of Title IV funds when the student has authorized UOP to apply financial aid funds to all open allowable charges.
If the student has authorized the University via the UOP FA Application (UOPFAA), [ACS] will apply funds as follows:
Other Open Charges – [ACS] will retain funds for other fees and charges that are discretionary educationally related expenses.
Other open charges include the following:



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