SIGNIFICANT DEFICIENCY 2022-003 Student Financial Assistance Program Cluster ? Title IV ? Federal Supplemental Educational Opportunity Grants (FSEOG) ? 84.007, Federal Work-Study Program (FWS) ? 84.033 ? Reporting Criteria or specific requirement ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is required to be submitted annually in order to receive funds for the campus-based programs. Condition During testing, items reported within the FISAP were found to be inaccurate or were unable to be substantiated due to a lack of supporting documentation. Cause Due to turnover within the Student Financial Aid office, certain documentation used to prepare the FISAP could not be located. Time sensitive reports were not saved at the time of the report preparation or could not be located during fieldwork. Because those reports were time sensitive, when they were rerun during fieldwork, they had small variances when compared to the numbers reported. Effect Inaccurate information may have been reported to the Department of Education. Context Of the sections that were tested, six contained reporting items that could not be substantiated or contained errors. Recommendation We recommend that all supporting documentation used in the preparation of the FISAP be saved in an easily identifiable location. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-004 Student Financial Assistance Program Cluster ? Title IV ?Federal Supplemental Opportunity Grants (FSEOG) ? 84.007, Federal Pell Grant Program ? 84.063, Federal Direct Student Loans (Direct Loan) ? 84.268 ? Cash Management and Special Tests and Provisions ? COD Reconciliation Criteria or specific requirement Per 34 CFR 668.162(b)(3), institutions must make disbursements to students as soon as administratively feasible, but no later than three business days following the receipt of funds. In addition, per 34 CFR 685.300(b)(5), institutions must, on a monthly basis, reconcile institutional records with Direct Loan funds received and disbursement records submitted. Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Cause Errors that occurred during the draw down process were not caught and corrected due to the lack of a sufficient monthly reconciliation occurring. Effect Disbursements were not made within required timeframes. In addition, funding was drawn from incorrect sources, and, as a result, the institution was required to return funds after COD discovered the variance. Context Pell in the amount of $348 and FSEOG in the amount of $10,085 were not disbursed within the required timeframe. Funding in the amount of $45,167 was drawn down from Direct Loans that should have been drawn down from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-003 Student Financial Assistance Program Cluster ? Title IV ? Federal Supplemental Educational Opportunity Grants (FSEOG) ? 84.007, Federal Work-Study Program (FWS) ? 84.033 ? Reporting Criteria or specific requirement ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is required to be submitted annually in order to receive funds for the campus-based programs. Condition During testing, items reported within the FISAP were found to be inaccurate or were unable to be substantiated due to a lack of supporting documentation. Cause Due to turnover within the Student Financial Aid office, certain documentation used to prepare the FISAP could not be located. Time sensitive reports were not saved at the time of the report preparation or could not be located during fieldwork. Because those reports were time sensitive, when they were rerun during fieldwork, they had small variances when compared to the numbers reported. Effect Inaccurate information may have been reported to the Department of Education. Context Of the sections that were tested, six contained reporting items that could not be substantiated or contained errors. Recommendation We recommend that all supporting documentation used in the preparation of the FISAP be saved in an easily identifiable location. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-004 Student Financial Assistance Program Cluster ? Title IV ?Federal Supplemental Opportunity Grants (FSEOG) ? 84.007, Federal Pell Grant Program ? 84.063, Federal Direct Student Loans (Direct Loan) ? 84.268 ? Cash Management and Special Tests and Provisions ? COD Reconciliation Criteria or specific requirement Per 34 CFR 668.162(b)(3), institutions must make disbursements to students as soon as administratively feasible, but no later than three business days following the receipt of funds. In addition, per 34 CFR 685.300(b)(5), institutions must, on a monthly basis, reconcile institutional records with Direct Loan funds received and disbursement records submitted. Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Cause Errors that occurred during the draw down process were not caught and corrected due to the lack of a sufficient monthly reconciliation occurring. Effect Disbursements were not made within required timeframes. In addition, funding was drawn from incorrect sources, and, as a result, the institution was required to return funds after COD discovered the variance. Context Pell in the amount of $348 and FSEOG in the amount of $10,085 were not disbursed within the required timeframe. Funding in the amount of $45,167 was drawn down from Direct Loans that should have been drawn down from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-005 Student Financial Assistance Program Cluster ? Title IV ? Federal Pell Grant Program ? 84.063 ? Eligibility Criteria or specific requirement A student?s annual Pell award should be calculated based on the cost of attendance and expected family contribution using the Payment and Disbursement Schedule for the student?s enrollment status. Condition During testing, it was discovered one student was incorrectly awarded Pell, and two others did not receive Pell disbursements for both eligible semesters attended during the year. Cause The error related to the student who was incorrectly awarded Pell occurred due to using the incorrect Payment and Disbursement Schedule for the student?s enrollment status. For the two students who did not receive a disbursement of Pell for both semesters, the disbursement was scheduled within the system but never posted. Effect Students received underpayments of Pell in the amount of $5,002. Estimated questioned costs total to $18,728. Context Of the 27 students tested for accurate Pell disbursements, three were found to have underpayments. Recommendation We recommend that the institution implement controls to ensure that all scheduled disbursements are ultimately posted. In addition, when calculating Pell awards, the Payment and Disbursement Schedule that matches the student?s enrollment status should be carefully selected and applied. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Federal Pell Grant Program ? 84.063 and Federal Direct Student Loans (Direct Loan) ? 84.268 ? Reporting Criteria or specific requirement Institutions must submit accurate Direct Loan and Pell Grant origination and disbursement records to the COD system. Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Cause One student?s COD records showed an incorrect amount of Direct Loan disbursements, and it appears to have been caused by a technical problem with the College?s software. Another student?s COD records showed no Pell disbursements even though they had received one. This occurred because COD requested a negative disbursement after the student?s verification status was not updated upon her completion of the verification process. Effect COD records were not accurately updated. Context Of the 17 students tested for COD records, one student?s COD records reported an extra $2,000 in Direct Loans that were not disbursed to the student?s account. An additional student who was not selected as part of the initial sample was later found to have $0 reported for Pell disbursements when actual disbursements to their account totaled to $3,248. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that COD records accurately reflect actual disbursements. In addition, we recommend that the institution implement a control to ensure that all completed verifications have been reported to COD. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-004 Student Financial Assistance Program Cluster ? Title IV ?Federal Supplemental Opportunity Grants (FSEOG) ? 84.007, Federal Pell Grant Program ? 84.063, Federal Direct Student Loans (Direct Loan) ? 84.268 ? Cash Management and Special Tests and Provisions ? COD Reconciliation Criteria or specific requirement Per 34 CFR 668.162(b)(3), institutions must make disbursements to students as soon as administratively feasible, but no later than three business days following the receipt of funds. In addition, per 34 CFR 685.300(b)(5), institutions must, on a monthly basis, reconcile institutional records with Direct Loan funds received and disbursement records submitted. Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Cause Errors that occurred during the draw down process were not caught and corrected due to the lack of a sufficient monthly reconciliation occurring. Effect Disbursements were not made within required timeframes. In addition, funding was drawn from incorrect sources, and, as a result, the institution was required to return funds after COD discovered the variance. Context Pell in the amount of $348 and FSEOG in the amount of $10,085 were not disbursed within the required timeframe. Funding in the amount of $45,167 was drawn down from Direct Loans that should have been drawn down from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Federal Pell Grant Program ? 84.063 and Federal Direct Student Loans (Direct Loan) ? 84.268 ? Reporting Criteria or specific requirement Institutions must submit accurate Direct Loan and Pell Grant origination and disbursement records to the COD system. Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Cause One student?s COD records showed an incorrect amount of Direct Loan disbursements, and it appears to have been caused by a technical problem with the College?s software. Another student?s COD records showed no Pell disbursements even though they had received one. This occurred because COD requested a negative disbursement after the student?s verification status was not updated upon her completion of the verification process. Effect COD records were not accurately updated. Context Of the 17 students tested for COD records, one student?s COD records reported an extra $2,000 in Direct Loans that were not disbursed to the student?s account. An additional student who was not selected as part of the initial sample was later found to have $0 reported for Pell disbursements when actual disbursements to their account totaled to $3,248. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that COD records accurately reflect actual disbursements. In addition, we recommend that the institution implement a control to ensure that all completed verifications have been reported to COD. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-007 Student Financial Assistance Program Cluster ? Title IV ? Federal Direct Student Loans (Direct Loan) ? 84.268 ? Eligibility Criteria or specific requirement The determination of need-based student financial assistance amounts is based upon financial need. Internal controls should be in place to ensure that students are awarded loans based upon the limits set by eligibility requirements. Condition During testing, it was discovered that two students were over awarded subsidized direct loans. Cause The institution did not recognize that an over award existed within the subsidized direct loans and that a portion of the subsidized loans would need to be changed to unsubsidized loans in order to avoid it. Effect Total over awards are $1,276. Total estimated over awards are $6,178. Context A total of 17 students were examined for proper award of direct loans. Of that number, there were two instances where the subsidized award amount was calculated incorrectly. This resulted in over awards totaling $1,276. Recommendation We recommend that the institution implement controls to ensure that direct loan award amounts are reviewed for accuracy prior to making awards to students. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-008 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Cash Management Criteria or specific requirement Per the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) for Higher Education Emergency Relief Fund (HEERF) II and the American Rescue Plan (ARP) for Higher Education Emergency Relief Fund (HEERF) III, the Student Aid Portion should be disbursed within 15 calendar days of the drawdown from G5, and the Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition During testing, it was discovered that funding was drawn down and not disbursed within the required timeframes. Cause The College was not aware of the cash management requirements associated with the program. Effect Funds were not disbursed timely. Context As of February 15, 2022, all HEERF Student portion awards had been drawn down, and the $313,928 HEERF III award amount was not disbursed to students until March 14, 2022. As of June 15, 2022, all HEERF Institutional and Strengthening Institutions Program (SIP) portion awards had been drawn down, and $98,532 remained to be disbursed as of year-end. Recommendation We recommend that the College review its reconciliation process and implement controls to ensure that funding is disbursed within the correct timeframe after being drawn down. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-009 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Activities Allowed or Unallowed Criteria or specific requirement Institutions may not condition the receipt of financial aid grants to students on continued or future enrollment in the institution and may not require a student to consent to the application of the financial aid grants to satisfy a student?s outstanding account balance as a condition of receipt of or eligibility for the financial aid grant. In addition, as it relates to expenditures under HEERF II and III, or for additional emergency financial aid grants made using other HEERF grant funds, the institution should not place any restrictions on the expenditure of those funds beyond what is allowed per statute, and the institution should not reimburse itself for any costs or expenses previously issued to students. Condition Students were awarded HEERF aid in June 2022 based upon their outstanding account balance, and they were not given the option to take the disbursement as anything other than a credit to their account. Cause The College was not aware that they could not require students to accept the aid as an application towards their outstanding account balance. Effect Students were restricted as to method of disbursement and expenditure of the funds. Context The total amount of June student aid HEERF awards totaled to $316,206. Recommendation We recommend that the institution carefully review guidance regarding new funding sources in order to ensure that all applicable requirements are being met. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Criteria or specific requirement Every calendar quarter, institutions are required to publicly post certain information on their website related to their HEERF program. Reports should be posted within 10 days following the end of the reporting period. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the ?Date of Report?. In addition, the Department of Education exercises reporting authority under 2 CFR section 200.328-329 to require that institutions submit an annual report on their uses of HEERF funds. Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Cause The Institution did not have proper controls in place to ensure that reports contained all required information, accurately reflected the records, and were posted timely. Effect Program information was not always reported timely or accurately. Context Reports were amended to add required information related to the estimated total number of eligible students and the total number of students who received aid, as well as to adjust expenditure amounts. Evidence supporting the date that reports were posted could not be determined for any quarterly reports. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-008 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Cash Management Criteria or specific requirement Per the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) for Higher Education Emergency Relief Fund (HEERF) II and the American Rescue Plan (ARP) for Higher Education Emergency Relief Fund (HEERF) III, the Student Aid Portion should be disbursed within 15 calendar days of the drawdown from G5, and the Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition During testing, it was discovered that funding was drawn down and not disbursed within the required timeframes. Cause The College was not aware of the cash management requirements associated with the program. Effect Funds were not disbursed timely. Context As of February 15, 2022, all HEERF Student portion awards had been drawn down, and the $313,928 HEERF III award amount was not disbursed to students until March 14, 2022. As of June 15, 2022, all HEERF Institutional and Strengthening Institutions Program (SIP) portion awards had been drawn down, and $98,532 remained to be disbursed as of year-end. Recommendation We recommend that the College review its reconciliation process and implement controls to ensure that funding is disbursed within the correct timeframe after being drawn down. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-010 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Allowable Costs or Cost Principles Criteria or specific requirement Per 2 CFR section 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. They also must support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity. Condition Admin expenses reported under the program did not have proper supporting documentation to reflect the salary or wages associated with the specific grant activities. Cause The College has not been required to make use of such records in the past with other grants or funding; therefore, they were not aware of this requirement associated with the HEERF program. Effect Inaccurate payroll costs may be reported under the program. Context The total amount of admin expenses is $7,200. Recommendation We recommend that the College review its controls and ensure that controls are implemented that meet Federal requirements related to payroll documentation. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Criteria or specific requirement Every calendar quarter, institutions are required to publicly post certain information on their website related to their HEERF program. Reports should be posted within 10 days following the end of the reporting period. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the ?Date of Report?. In addition, the Department of Education exercises reporting authority under 2 CFR section 200.328-329 to require that institutions submit an annual report on their uses of HEERF funds. Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Cause The Institution did not have proper controls in place to ensure that reports contained all required information, accurately reflected the records, and were posted timely. Effect Program information was not always reported timely or accurately. Context Reports were amended to add required information related to the estimated total number of eligible students and the total number of students who received aid, as well as to adjust expenditure amounts. Evidence supporting the date that reports were posted could not be determined for any quarterly reports. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-008 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Cash Management Criteria or specific requirement Per the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) for Higher Education Emergency Relief Fund (HEERF) II and the American Rescue Plan (ARP) for Higher Education Emergency Relief Fund (HEERF) III, the Student Aid Portion should be disbursed within 15 calendar days of the drawdown from G5, and the Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition During testing, it was discovered that funding was drawn down and not disbursed within the required timeframes. Cause The College was not aware of the cash management requirements associated with the program. Effect Funds were not disbursed timely. Context As of February 15, 2022, all HEERF Student portion awards had been drawn down, and the $313,928 HEERF III award amount was not disbursed to students until March 14, 2022. As of June 15, 2022, all HEERF Institutional and Strengthening Institutions Program (SIP) portion awards had been drawn down, and $98,532 remained to be disbursed as of year-end. Recommendation We recommend that the College review its reconciliation process and implement controls to ensure that funding is disbursed within the correct timeframe after being drawn down. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Criteria or specific requirement Every calendar quarter, institutions are required to publicly post certain information on their website related to their HEERF program. Reports should be posted within 10 days following the end of the reporting period. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the ?Date of Report?. In addition, the Department of Education exercises reporting authority under 2 CFR section 200.328-329 to require that institutions submit an annual report on their uses of HEERF funds. Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Cause The Institution did not have proper controls in place to ensure that reports contained all required information, accurately reflected the records, and were posted timely. Effect Program information was not always reported timely or accurately. Context Reports were amended to add required information related to the estimated total number of eligible students and the total number of students who received aid, as well as to adjust expenditure amounts. Evidence supporting the date that reports were posted could not be determined for any quarterly reports. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-003 Student Financial Assistance Program Cluster ? Title IV ? Federal Supplemental Educational Opportunity Grants (FSEOG) ? 84.007, Federal Work-Study Program (FWS) ? 84.033 ? Reporting Criteria or specific requirement ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is required to be submitted annually in order to receive funds for the campus-based programs. Condition During testing, items reported within the FISAP were found to be inaccurate or were unable to be substantiated due to a lack of supporting documentation. Cause Due to turnover within the Student Financial Aid office, certain documentation used to prepare the FISAP could not be located. Time sensitive reports were not saved at the time of the report preparation or could not be located during fieldwork. Because those reports were time sensitive, when they were rerun during fieldwork, they had small variances when compared to the numbers reported. Effect Inaccurate information may have been reported to the Department of Education. Context Of the sections that were tested, six contained reporting items that could not be substantiated or contained errors. Recommendation We recommend that all supporting documentation used in the preparation of the FISAP be saved in an easily identifiable location. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-004 Student Financial Assistance Program Cluster ? Title IV ?Federal Supplemental Opportunity Grants (FSEOG) ? 84.007, Federal Pell Grant Program ? 84.063, Federal Direct Student Loans (Direct Loan) ? 84.268 ? Cash Management and Special Tests and Provisions ? COD Reconciliation Criteria or specific requirement Per 34 CFR 668.162(b)(3), institutions must make disbursements to students as soon as administratively feasible, but no later than three business days following the receipt of funds. In addition, per 34 CFR 685.300(b)(5), institutions must, on a monthly basis, reconcile institutional records with Direct Loan funds received and disbursement records submitted. Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Cause Errors that occurred during the draw down process were not caught and corrected due to the lack of a sufficient monthly reconciliation occurring. Effect Disbursements were not made within required timeframes. In addition, funding was drawn from incorrect sources, and, as a result, the institution was required to return funds after COD discovered the variance. Context Pell in the amount of $348 and FSEOG in the amount of $10,085 were not disbursed within the required timeframe. Funding in the amount of $45,167 was drawn down from Direct Loans that should have been drawn down from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-003 Student Financial Assistance Program Cluster ? Title IV ? Federal Supplemental Educational Opportunity Grants (FSEOG) ? 84.007, Federal Work-Study Program (FWS) ? 84.033 ? Reporting Criteria or specific requirement ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is required to be submitted annually in order to receive funds for the campus-based programs. Condition During testing, items reported within the FISAP were found to be inaccurate or were unable to be substantiated due to a lack of supporting documentation. Cause Due to turnover within the Student Financial Aid office, certain documentation used to prepare the FISAP could not be located. Time sensitive reports were not saved at the time of the report preparation or could not be located during fieldwork. Because those reports were time sensitive, when they were rerun during fieldwork, they had small variances when compared to the numbers reported. Effect Inaccurate information may have been reported to the Department of Education. Context Of the sections that were tested, six contained reporting items that could not be substantiated or contained errors. Recommendation We recommend that all supporting documentation used in the preparation of the FISAP be saved in an easily identifiable location. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-004 Student Financial Assistance Program Cluster ? Title IV ?Federal Supplemental Opportunity Grants (FSEOG) ? 84.007, Federal Pell Grant Program ? 84.063, Federal Direct Student Loans (Direct Loan) ? 84.268 ? Cash Management and Special Tests and Provisions ? COD Reconciliation Criteria or specific requirement Per 34 CFR 668.162(b)(3), institutions must make disbursements to students as soon as administratively feasible, but no later than three business days following the receipt of funds. In addition, per 34 CFR 685.300(b)(5), institutions must, on a monthly basis, reconcile institutional records with Direct Loan funds received and disbursement records submitted. Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Cause Errors that occurred during the draw down process were not caught and corrected due to the lack of a sufficient monthly reconciliation occurring. Effect Disbursements were not made within required timeframes. In addition, funding was drawn from incorrect sources, and, as a result, the institution was required to return funds after COD discovered the variance. Context Pell in the amount of $348 and FSEOG in the amount of $10,085 were not disbursed within the required timeframe. Funding in the amount of $45,167 was drawn down from Direct Loans that should have been drawn down from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-005 Student Financial Assistance Program Cluster ? Title IV ? Federal Pell Grant Program ? 84.063 ? Eligibility Criteria or specific requirement A student?s annual Pell award should be calculated based on the cost of attendance and expected family contribution using the Payment and Disbursement Schedule for the student?s enrollment status. Condition During testing, it was discovered one student was incorrectly awarded Pell, and two others did not receive Pell disbursements for both eligible semesters attended during the year. Cause The error related to the student who was incorrectly awarded Pell occurred due to using the incorrect Payment and Disbursement Schedule for the student?s enrollment status. For the two students who did not receive a disbursement of Pell for both semesters, the disbursement was scheduled within the system but never posted. Effect Students received underpayments of Pell in the amount of $5,002. Estimated questioned costs total to $18,728. Context Of the 27 students tested for accurate Pell disbursements, three were found to have underpayments. Recommendation We recommend that the institution implement controls to ensure that all scheduled disbursements are ultimately posted. In addition, when calculating Pell awards, the Payment and Disbursement Schedule that matches the student?s enrollment status should be carefully selected and applied. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Federal Pell Grant Program ? 84.063 and Federal Direct Student Loans (Direct Loan) ? 84.268 ? Reporting Criteria or specific requirement Institutions must submit accurate Direct Loan and Pell Grant origination and disbursement records to the COD system. Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Cause One student?s COD records showed an incorrect amount of Direct Loan disbursements, and it appears to have been caused by a technical problem with the College?s software. Another student?s COD records showed no Pell disbursements even though they had received one. This occurred because COD requested a negative disbursement after the student?s verification status was not updated upon her completion of the verification process. Effect COD records were not accurately updated. Context Of the 17 students tested for COD records, one student?s COD records reported an extra $2,000 in Direct Loans that were not disbursed to the student?s account. An additional student who was not selected as part of the initial sample was later found to have $0 reported for Pell disbursements when actual disbursements to their account totaled to $3,248. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that COD records accurately reflect actual disbursements. In addition, we recommend that the institution implement a control to ensure that all completed verifications have been reported to COD. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-004 Student Financial Assistance Program Cluster ? Title IV ?Federal Supplemental Opportunity Grants (FSEOG) ? 84.007, Federal Pell Grant Program ? 84.063, Federal Direct Student Loans (Direct Loan) ? 84.268 ? Cash Management and Special Tests and Provisions ? COD Reconciliation Criteria or specific requirement Per 34 CFR 668.162(b)(3), institutions must make disbursements to students as soon as administratively feasible, but no later than three business days following the receipt of funds. In addition, per 34 CFR 685.300(b)(5), institutions must, on a monthly basis, reconcile institutional records with Direct Loan funds received and disbursement records submitted. Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Cause Errors that occurred during the draw down process were not caught and corrected due to the lack of a sufficient monthly reconciliation occurring. Effect Disbursements were not made within required timeframes. In addition, funding was drawn from incorrect sources, and, as a result, the institution was required to return funds after COD discovered the variance. Context Pell in the amount of $348 and FSEOG in the amount of $10,085 were not disbursed within the required timeframe. Funding in the amount of $45,167 was drawn down from Direct Loans that should have been drawn down from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Federal Pell Grant Program ? 84.063 and Federal Direct Student Loans (Direct Loan) ? 84.268 ? Reporting Criteria or specific requirement Institutions must submit accurate Direct Loan and Pell Grant origination and disbursement records to the COD system. Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Cause One student?s COD records showed an incorrect amount of Direct Loan disbursements, and it appears to have been caused by a technical problem with the College?s software. Another student?s COD records showed no Pell disbursements even though they had received one. This occurred because COD requested a negative disbursement after the student?s verification status was not updated upon her completion of the verification process. Effect COD records were not accurately updated. Context Of the 17 students tested for COD records, one student?s COD records reported an extra $2,000 in Direct Loans that were not disbursed to the student?s account. An additional student who was not selected as part of the initial sample was later found to have $0 reported for Pell disbursements when actual disbursements to their account totaled to $3,248. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that COD records accurately reflect actual disbursements. In addition, we recommend that the institution implement a control to ensure that all completed verifications have been reported to COD. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-007 Student Financial Assistance Program Cluster ? Title IV ? Federal Direct Student Loans (Direct Loan) ? 84.268 ? Eligibility Criteria or specific requirement The determination of need-based student financial assistance amounts is based upon financial need. Internal controls should be in place to ensure that students are awarded loans based upon the limits set by eligibility requirements. Condition During testing, it was discovered that two students were over awarded subsidized direct loans. Cause The institution did not recognize that an over award existed within the subsidized direct loans and that a portion of the subsidized loans would need to be changed to unsubsidized loans in order to avoid it. Effect Total over awards are $1,276. Total estimated over awards are $6,178. Context A total of 17 students were examined for proper award of direct loans. Of that number, there were two instances where the subsidized award amount was calculated incorrectly. This resulted in over awards totaling $1,276. Recommendation We recommend that the institution implement controls to ensure that direct loan award amounts are reviewed for accuracy prior to making awards to students. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-008 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Cash Management Criteria or specific requirement Per the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) for Higher Education Emergency Relief Fund (HEERF) II and the American Rescue Plan (ARP) for Higher Education Emergency Relief Fund (HEERF) III, the Student Aid Portion should be disbursed within 15 calendar days of the drawdown from G5, and the Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition During testing, it was discovered that funding was drawn down and not disbursed within the required timeframes. Cause The College was not aware of the cash management requirements associated with the program. Effect Funds were not disbursed timely. Context As of February 15, 2022, all HEERF Student portion awards had been drawn down, and the $313,928 HEERF III award amount was not disbursed to students until March 14, 2022. As of June 15, 2022, all HEERF Institutional and Strengthening Institutions Program (SIP) portion awards had been drawn down, and $98,532 remained to be disbursed as of year-end. Recommendation We recommend that the College review its reconciliation process and implement controls to ensure that funding is disbursed within the correct timeframe after being drawn down. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-009 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Activities Allowed or Unallowed Criteria or specific requirement Institutions may not condition the receipt of financial aid grants to students on continued or future enrollment in the institution and may not require a student to consent to the application of the financial aid grants to satisfy a student?s outstanding account balance as a condition of receipt of or eligibility for the financial aid grant. In addition, as it relates to expenditures under HEERF II and III, or for additional emergency financial aid grants made using other HEERF grant funds, the institution should not place any restrictions on the expenditure of those funds beyond what is allowed per statute, and the institution should not reimburse itself for any costs or expenses previously issued to students. Condition Students were awarded HEERF aid in June 2022 based upon their outstanding account balance, and they were not given the option to take the disbursement as anything other than a credit to their account. Cause The College was not aware that they could not require students to accept the aid as an application towards their outstanding account balance. Effect Students were restricted as to method of disbursement and expenditure of the funds. Context The total amount of June student aid HEERF awards totaled to $316,206. Recommendation We recommend that the institution carefully review guidance regarding new funding sources in order to ensure that all applicable requirements are being met. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Criteria or specific requirement Every calendar quarter, institutions are required to publicly post certain information on their website related to their HEERF program. Reports should be posted within 10 days following the end of the reporting period. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the ?Date of Report?. In addition, the Department of Education exercises reporting authority under 2 CFR section 200.328-329 to require that institutions submit an annual report on their uses of HEERF funds. Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Cause The Institution did not have proper controls in place to ensure that reports contained all required information, accurately reflected the records, and were posted timely. Effect Program information was not always reported timely or accurately. Context Reports were amended to add required information related to the estimated total number of eligible students and the total number of students who received aid, as well as to adjust expenditure amounts. Evidence supporting the date that reports were posted could not be determined for any quarterly reports. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-008 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Cash Management Criteria or specific requirement Per the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) for Higher Education Emergency Relief Fund (HEERF) II and the American Rescue Plan (ARP) for Higher Education Emergency Relief Fund (HEERF) III, the Student Aid Portion should be disbursed within 15 calendar days of the drawdown from G5, and the Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition During testing, it was discovered that funding was drawn down and not disbursed within the required timeframes. Cause The College was not aware of the cash management requirements associated with the program. Effect Funds were not disbursed timely. Context As of February 15, 2022, all HEERF Student portion awards had been drawn down, and the $313,928 HEERF III award amount was not disbursed to students until March 14, 2022. As of June 15, 2022, all HEERF Institutional and Strengthening Institutions Program (SIP) portion awards had been drawn down, and $98,532 remained to be disbursed as of year-end. Recommendation We recommend that the College review its reconciliation process and implement controls to ensure that funding is disbursed within the correct timeframe after being drawn down. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-010 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Allowable Costs or Cost Principles Criteria or specific requirement Per 2 CFR section 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. They also must support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity. Condition Admin expenses reported under the program did not have proper supporting documentation to reflect the salary or wages associated with the specific grant activities. Cause The College has not been required to make use of such records in the past with other grants or funding; therefore, they were not aware of this requirement associated with the HEERF program. Effect Inaccurate payroll costs may be reported under the program. Context The total amount of admin expenses is $7,200. Recommendation We recommend that the College review its controls and ensure that controls are implemented that meet Federal requirements related to payroll documentation. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Criteria or specific requirement Every calendar quarter, institutions are required to publicly post certain information on their website related to their HEERF program. Reports should be posted within 10 days following the end of the reporting period. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the ?Date of Report?. In addition, the Department of Education exercises reporting authority under 2 CFR section 200.328-329 to require that institutions submit an annual report on their uses of HEERF funds. Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Cause The Institution did not have proper controls in place to ensure that reports contained all required information, accurately reflected the records, and were posted timely. Effect Program information was not always reported timely or accurately. Context Reports were amended to add required information related to the estimated total number of eligible students and the total number of students who received aid, as well as to adjust expenditure amounts. Evidence supporting the date that reports were posted could not be determined for any quarterly reports. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Views of responsible officials and planned corrective actions See corrective action plan.
MATERIAL WEAKNESS 2022-008 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Cash Management Criteria or specific requirement Per the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) for Higher Education Emergency Relief Fund (HEERF) II and the American Rescue Plan (ARP) for Higher Education Emergency Relief Fund (HEERF) III, the Student Aid Portion should be disbursed within 15 calendar days of the drawdown from G5, and the Institutional Aid Portion should be disbursed within 3 calendar days of the drawdown from G5. Condition During testing, it was discovered that funding was drawn down and not disbursed within the required timeframes. Cause The College was not aware of the cash management requirements associated with the program. Effect Funds were not disbursed timely. Context As of February 15, 2022, all HEERF Student portion awards had been drawn down, and the $313,928 HEERF III award amount was not disbursed to students until March 14, 2022. As of June 15, 2022, all HEERF Institutional and Strengthening Institutions Program (SIP) portion awards had been drawn down, and $98,532 remained to be disbursed as of year-end. Recommendation We recommend that the College review its reconciliation process and implement controls to ensure that funding is disbursed within the correct timeframe after being drawn down. Views of responsible officials and planned corrective actions See corrective action plan.
SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Criteria or specific requirement Every calendar quarter, institutions are required to publicly post certain information on their website related to their HEERF program. Reports should be posted within 10 days following the end of the reporting period. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the ?Date of Report?. In addition, the Department of Education exercises reporting authority under 2 CFR section 200.328-329 to require that institutions submit an annual report on their uses of HEERF funds. Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Cause The Institution did not have proper controls in place to ensure that reports contained all required information, accurately reflected the records, and were posted timely. Effect Program information was not always reported timely or accurately. Context Reports were amended to add required information related to the estimated total number of eligible students and the total number of students who received aid, as well as to adjust expenditure amounts. Evidence supporting the date that reports were posted could not be determined for any quarterly reports. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Views of responsible officials and planned corrective actions See corrective action plan.