FINDING 2022-002: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twelve drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an error in Steps 1 and 5 of the Return to Title IV refund calculation. Effect: As a result, the Institution is holding funds that need to be returned to the Department. Question Costs: $1,592 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $1,592 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-003: LATE REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twelve drop students in our sample and noted two late refunds. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-004. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $6,908 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-001: UNDERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, seventeen of which were Pell Grant recipients, and two students did not receive the full amount of their allowed Pell grants. The students were eligible for $4,035 but received $2,958. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-001. Cause: The condition was caused by an overisght in the financial aid department. Effect: The result is the students did not receive $1,077 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution credit $1,077 to the students' accounts. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-002: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twelve drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an error in Steps 1 and 5 of the Return to Title IV refund calculation. Effect: As a result, the Institution is holding funds that need to be returned to the Department. Question Costs: $1,592 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $1,592 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-003: LATE REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twelve drop students in our sample and noted two late refunds. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-004. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $6,908 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-004: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement the required procurement policies. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-005: INSUFFICIENT STANDARD OF CONDUCT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts (2 C.F.R. ?200.318(c) and 48 C.F.R. ?? 52.203-13 and 52.303-16). Condition: The Institution failed to implement the required standards of conduct. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the standards of conduct. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-006: INACCURATE REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: Section 18004(e) of the CARES Act directs schools receiving funds under Section 18004 of the Act to submit a report to The Department describing the use of funds distributed from HEERF. There are three components to reporting for HEERF that are applicable to proprietary schools: 1) Quarterly public reporting on the (a)(1) Student Aid Portion; 2) Quarterly public reporting on the (a)(1) Condition: The Institution incorrectly reported the total amount of funds received and the total amount of quarterly expenditures on its Institutional report for the quarter ended June 30, 2022. The Institution's student quarterly report for the quarter ended March 31, 2022 is missing one of the seven required data elements set forth by the Department. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution understated the amount of total funds received and total institutional expenditures for the quarter ended June 30, 2022, and did not list the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission on its student quarterly report for the quarter ended March 31, 2022. Question Costs: $0 Recommendation: We recommend the Institution make corrections to the applicable reports. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-007: UNTIMELY REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: As required under the CARES Act Section 18004(e) and clarified under Federal Register August 31, 2020 (85 FR 53802) and the CRRSAA Section 314(e), an Institution must publicly post the total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) as of the date of submission and updated every 45 days thereafter (subsequently changed to every quarter) and must publicly post Quarterly Budget and Expenditure Reporting forms every quarter to satisfy the Condition: The Institution was late in publicly posting its Institutional Expenditure reports for the quarters ended December 31, 2021 and March 31, 2022. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is that the Department of Education and general public were not made aware of the Institution?s quarterly institutional expenditures in a timely manner. Question Costs: $0 Recommendation: We recommend the Institution increase controls over reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-008: CASH MANAGEMENT - UNTIMELY DISBURSEMENTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERGENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Cash Management (C.) - Student Grant Disbursements Criteria: For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department's G5 grant systems and all other ALN's should be disbursed within 3 calendar days of the drawdown from G5. Condition: The Institution failed to disburse their ARP HEERF III student grants within 15 calendar days of the drawdown from G5. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is students were not disbursed emergency grant funds in a timely manner. The Institution drew down their ARP HEERF III student grant award on August 12, 2021 and did not disburse funds to students until March 1, 2022. Question Costs: $293,027 Recommendation: We recommend the Institution increase controls over cash management and await further guidance from the Department. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-004: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement the required procurement policies. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-005: INSUFFICIENT STANDARD OF CONDUCT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts (2 C.F.R. ?200.318(c) and 48 C.F.R. ?? 52.203-13 and 52.303-16). Condition: The Institution failed to implement the required standards of conduct. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the standards of conduct. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-006: INACCURATE REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: Section 18004(e) of the CARES Act directs schools receiving funds under Section 18004 of the Act to submit a report to The Department describing the use of funds distributed from HEERF. There are three components to reporting for HEERF that are applicable to proprietary schools: 1) Quarterly public reporting on the (a)(1) Student Aid Portion; 2) Quarterly public reporting on the (a)(1) Condition: The Institution incorrectly reported the total amount of funds received and the total amount of quarterly expenditures on its Institutional report for the quarter ended June 30, 2022. The Institution's student quarterly report for the quarter ended March 31, 2022 is missing one of the seven required data elements set forth by the Department. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution understated the amount of total funds received and total institutional expenditures for the quarter ended June 30, 2022, and did not list the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission on its student quarterly report for the quarter ended March 31, 2022. Question Costs: $0 Recommendation: We recommend the Institution make corrections to the applicable reports. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-007: UNTIMELY REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: As required under the CARES Act Section 18004(e) and clarified under Federal Register August 31, 2020 (85 FR 53802) and the CRRSAA Section 314(e), an Institution must publicly post the total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) as of the date of submission and updated every 45 days thereafter (subsequently changed to every quarter) and must publicly post Quarterly Budget and Expenditure Reporting forms every quarter to satisfy the Condition: The Institution was late in publicly posting its Institutional Expenditure reports for the quarters ended December 31, 2021 and March 31, 2022. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is that the Department of Education and general public were not made aware of the Institution?s quarterly institutional expenditures in a timely manner. Question Costs: $0 Recommendation: We recommend the Institution increase controls over reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-008: CASH MANAGEMENT - UNTIMELY DISBURSEMENTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERGENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Cash Management (C.) - Student Grant Disbursements Criteria: For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department's G5 grant systems and all other ALN's should be disbursed within 3 calendar days of the drawdown from G5. Condition: The Institution failed to disburse their ARP HEERF III student grants within 15 calendar days of the drawdown from G5. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is students were not disbursed emergency grant funds in a timely manner. The Institution drew down their ARP HEERF III student grant award on August 12, 2021 and did not disburse funds to students until March 1, 2022. Question Costs: $293,027 Recommendation: We recommend the Institution increase controls over cash management and await further guidance from the Department. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-002: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twelve drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an error in Steps 1 and 5 of the Return to Title IV refund calculation. Effect: As a result, the Institution is holding funds that need to be returned to the Department. Question Costs: $1,592 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $1,592 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-003: LATE REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twelve drop students in our sample and noted two late refunds. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-004. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $6,908 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-001: UNDERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, seventeen of which were Pell Grant recipients, and two students did not receive the full amount of their allowed Pell grants. The students were eligible for $4,035 but received $2,958. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-001. Cause: The condition was caused by an overisght in the financial aid department. Effect: The result is the students did not receive $1,077 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution credit $1,077 to the students' accounts. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-002: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twelve drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an error in Steps 1 and 5 of the Return to Title IV refund calculation. Effect: As a result, the Institution is holding funds that need to be returned to the Department. Question Costs: $1,592 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $1,592 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-003: LATE REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twelve drop students in our sample and noted two late refunds. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-004. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $6,908 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-004: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement the required procurement policies. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-005: INSUFFICIENT STANDARD OF CONDUCT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts (2 C.F.R. ?200.318(c) and 48 C.F.R. ?? 52.203-13 and 52.303-16). Condition: The Institution failed to implement the required standards of conduct. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the standards of conduct. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-006: INACCURATE REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: Section 18004(e) of the CARES Act directs schools receiving funds under Section 18004 of the Act to submit a report to The Department describing the use of funds distributed from HEERF. There are three components to reporting for HEERF that are applicable to proprietary schools: 1) Quarterly public reporting on the (a)(1) Student Aid Portion; 2) Quarterly public reporting on the (a)(1) Condition: The Institution incorrectly reported the total amount of funds received and the total amount of quarterly expenditures on its Institutional report for the quarter ended June 30, 2022. The Institution's student quarterly report for the quarter ended March 31, 2022 is missing one of the seven required data elements set forth by the Department. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution understated the amount of total funds received and total institutional expenditures for the quarter ended June 30, 2022, and did not list the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission on its student quarterly report for the quarter ended March 31, 2022. Question Costs: $0 Recommendation: We recommend the Institution make corrections to the applicable reports. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-007: UNTIMELY REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: As required under the CARES Act Section 18004(e) and clarified under Federal Register August 31, 2020 (85 FR 53802) and the CRRSAA Section 314(e), an Institution must publicly post the total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) as of the date of submission and updated every 45 days thereafter (subsequently changed to every quarter) and must publicly post Quarterly Budget and Expenditure Reporting forms every quarter to satisfy the Condition: The Institution was late in publicly posting its Institutional Expenditure reports for the quarters ended December 31, 2021 and March 31, 2022. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is that the Department of Education and general public were not made aware of the Institution?s quarterly institutional expenditures in a timely manner. Question Costs: $0 Recommendation: We recommend the Institution increase controls over reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-008: CASH MANAGEMENT - UNTIMELY DISBURSEMENTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERGENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Cash Management (C.) - Student Grant Disbursements Criteria: For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department's G5 grant systems and all other ALN's should be disbursed within 3 calendar days of the drawdown from G5. Condition: The Institution failed to disburse their ARP HEERF III student grants within 15 calendar days of the drawdown from G5. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is students were not disbursed emergency grant funds in a timely manner. The Institution drew down their ARP HEERF III student grant award on August 12, 2021 and did not disburse funds to students until March 1, 2022. Question Costs: $293,027 Recommendation: We recommend the Institution increase controls over cash management and await further guidance from the Department. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-004: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement the required procurement policies. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-005: INSUFFICIENT STANDARD OF CONDUCT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts (2 C.F.R. ?200.318(c) and 48 C.F.R. ?? 52.203-13 and 52.303-16). Condition: The Institution failed to implement the required standards of conduct. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the standards of conduct. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-006: INACCURATE REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: Section 18004(e) of the CARES Act directs schools receiving funds under Section 18004 of the Act to submit a report to The Department describing the use of funds distributed from HEERF. There are three components to reporting for HEERF that are applicable to proprietary schools: 1) Quarterly public reporting on the (a)(1) Student Aid Portion; 2) Quarterly public reporting on the (a)(1) Condition: The Institution incorrectly reported the total amount of funds received and the total amount of quarterly expenditures on its Institutional report for the quarter ended June 30, 2022. The Institution's student quarterly report for the quarter ended March 31, 2022 is missing one of the seven required data elements set forth by the Department. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution understated the amount of total funds received and total institutional expenditures for the quarter ended June 30, 2022, and did not list the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission on its student quarterly report for the quarter ended March 31, 2022. Question Costs: $0 Recommendation: We recommend the Institution make corrections to the applicable reports. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-007: UNTIMELY REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: As required under the CARES Act Section 18004(e) and clarified under Federal Register August 31, 2020 (85 FR 53802) and the CRRSAA Section 314(e), an Institution must publicly post the total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) as of the date of submission and updated every 45 days thereafter (subsequently changed to every quarter) and must publicly post Quarterly Budget and Expenditure Reporting forms every quarter to satisfy the Condition: The Institution was late in publicly posting its Institutional Expenditure reports for the quarters ended December 31, 2021 and March 31, 2022. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is that the Department of Education and general public were not made aware of the Institution?s quarterly institutional expenditures in a timely manner. Question Costs: $0 Recommendation: We recommend the Institution increase controls over reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2022-008: CASH MANAGEMENT - UNTIMELY DISBURSEMENTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERGENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Cash Management (C.) - Student Grant Disbursements Criteria: For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department's G5 grant systems and all other ALN's should be disbursed within 3 calendar days of the drawdown from G5. Condition: The Institution failed to disburse their ARP HEERF III student grants within 15 calendar days of the drawdown from G5. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is students were not disbursed emergency grant funds in a timely manner. The Institution drew down their ARP HEERF III student grant award on August 12, 2021 and did not disburse funds to students until March 1, 2022. Question Costs: $293,027 Recommendation: We recommend the Institution increase controls over cash management and await further guidance from the Department. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.