Audit 19960

FY End
2022-06-30
Total Expended
$2.19M
Findings
28
Programs
5
Organization: Cottey College (MO)
Year: 2022 Accepted: 2023-05-07

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
24031 2022-002 Significant Deficiency - N
24032 2022-003 Significant Deficiency - L
24033 2022-004 Significant Deficiency Yes N
24034 2022-002 Significant Deficiency - N
24035 2022-003 Significant Deficiency - L
24036 2022-004 Significant Deficiency Yes N
24037 2022-002 Significant Deficiency - N
24038 2022-003 Significant Deficiency - L
24039 2022-004 Significant Deficiency Yes N
24040 2022-002 Significant Deficiency - N
24041 2022-003 Significant Deficiency - L
24042 2022-004 Significant Deficiency Yes N
24043 2022-005 Significant Deficiency - L
24044 2022-005 Significant Deficiency - L
600473 2022-002 Significant Deficiency - N
600474 2022-003 Significant Deficiency - L
600475 2022-004 Significant Deficiency Yes N
600476 2022-002 Significant Deficiency - N
600477 2022-003 Significant Deficiency - L
600478 2022-004 Significant Deficiency Yes N
600479 2022-002 Significant Deficiency - N
600480 2022-003 Significant Deficiency - L
600481 2022-004 Significant Deficiency Yes N
600482 2022-002 Significant Deficiency - N
600483 2022-003 Significant Deficiency - L
600484 2022-004 Significant Deficiency Yes N
600485 2022-005 Significant Deficiency - L
600486 2022-005 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $999,516 Yes 3
84.063 Federal Pell Grant Program $637,109 Yes 3
84.425 Education Stabilization Fund $431,091 Yes 1
84.033 Federal Work-Study Program $29,746 Yes 3
84.007 Federal Supplemental Educational Opportunity Grants $18,741 Yes 3

Contacts

Name Title Type
J4C4KJBAAM33 Kimberly Marshall Auditee
4176678181 Deirdre Hodgson, CPA Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting.Such expenditures are recognized following the cost principles contained in the UniformGuidance, wherein certain types of expenditures are not allowable or are limited as toreimbursement. Negative amounts shown on the Schedule represent adjustments or creditsmade in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The purpose of the schedule of expenditures of federal awards (the Schedule) is to present a summary of those activities of Cottey College (the College) that have been financed by the U.S. government (federal awards). Federal awards received directly from federal agencies are included in the Schedule, as are federal guaranteed loans disbursed by other sources. Additionally, all federal awards passed through from other entities have been included in the Schedule. The College is required to match certain grant agreements, as defined in the grants, and these matching amounts are not included in the Schedule. The information in the Schedule is presented in accordance with requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Cottey College.

Finding Details

Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Funding Assistance Numbers: 84.425E and 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? The December 31, 2021, and March 31, 2022, student quarterly reports did not have proper documentation of expenditure. ? The December 31, 2021, and March 31, 2022, student quarterly reports were not posted timely. ? The March 31, 2022, Institutional quarterly report was not posted timely. ? The December 31, 2021, and March 31, 2022, institutional quarterly reports were not properly reviewed prior to submission. ? The December 31, 2021, annual report was not properly reviewed prior to submission. Question Cost: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that it posted the reporting timely and accurately. Effect: The College did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Funding Assistance Numbers: 84.425E and 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? The December 31, 2021, and March 31, 2022, student quarterly reports did not have proper documentation of expenditure. ? The December 31, 2021, and March 31, 2022, student quarterly reports were not posted timely. ? The March 31, 2022, Institutional quarterly report was not posted timely. ? The December 31, 2021, and March 31, 2022, institutional quarterly reports were not properly reviewed prior to submission. ? The December 31, 2021, annual report was not properly reviewed prior to submission. Question Cost: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that it posted the reporting timely and accurately. Effect: The College did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Funding Assistance Numbers: 84.425E and 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? The December 31, 2021, and March 31, 2022, student quarterly reports did not have proper documentation of expenditure. ? The December 31, 2021, and March 31, 2022, student quarterly reports were not posted timely. ? The March 31, 2022, Institutional quarterly report was not posted timely. ? The December 31, 2021, and March 31, 2022, institutional quarterly reports were not properly reviewed prior to submission. ? The December 31, 2021, annual report was not properly reviewed prior to submission. Question Cost: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that it posted the reporting timely and accurately. Effect: The College did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Funding Assistance Numbers: 84.425E and 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? The December 31, 2021, and March 31, 2022, student quarterly reports did not have proper documentation of expenditure. ? The December 31, 2021, and March 31, 2022, student quarterly reports were not posted timely. ? The March 31, 2022, Institutional quarterly report was not posted timely. ? The December 31, 2021, and March 31, 2022, institutional quarterly reports were not properly reviewed prior to submission. ? The December 31, 2021, annual report was not properly reviewed prior to submission. Question Cost: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that it posted the reporting timely and accurately. Effect: The College did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.