Finding No. 2022-004 ? Enrollment Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-004 ? Enrollment Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding No. 2022-002 ? Higher Education Emergency Relief Funds Reporting (Repeat Finding ? 2021-001) Federal Agency: U.S. Department of Education (DOE) Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The College is required to publicly report both timely and accurately on its website aggregate amounts expended for Higher Education Emergency Relief Funds (HEERF) each quarterly reporting period from assistance listings 84.425F Institutional Portion and 84.425M Strengthening Institutions Program. The College must post the quarterly report form no later than 10 days after the end of each calendar quarter publicly on the College?s website on the same page the reports of the College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Additionally, the amounts reported in the quarterly reports must reconcile to the underlying documentation to ensure accuracy. Condition: As it related to the institutional portion of HEERF, the College inaccurately reported the quarterly amount drawn from the G5 system and reported amounts in the wrong category (misclassified). Questioned Costs: None. Prevalence: Identified in 2 out of 4 institutional quarterly reports tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The College was not in compliance with reporting requirements for HEERF as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures have been taken.
Finding No. 2022-003 ? Higher Education Emergency Relief Funds Earmarking Federal Agency: U.S. Department of Education Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The American Rescue Plan created a new requirement that a portion of the HEERF III institutional funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. Condition: There was no evidence that direct outreach was performed during the fiscal year in which the remaining federal fundings under the award were expended. Questioned Costs: None. Prevalence: There was no evidence that direct outreach occurred as required by the program. Effect: Not complying with requirements outlined within applicable grant agreements could result in the DOE withholding payments to the College. Cause: This issue is a result of a lack of proper understanding of applicable requirements. Recommendation: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, we recommend that management implement a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-002 ? Higher Education Emergency Relief Funds Reporting (Repeat Finding ? 2021-001) Federal Agency: U.S. Department of Education (DOE) Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The College is required to publicly report both timely and accurately on its website aggregate amounts expended for Higher Education Emergency Relief Funds (HEERF) each quarterly reporting period from assistance listings 84.425F Institutional Portion and 84.425M Strengthening Institutions Program. The College must post the quarterly report form no later than 10 days after the end of each calendar quarter publicly on the College?s website on the same page the reports of the College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Additionally, the amounts reported in the quarterly reports must reconcile to the underlying documentation to ensure accuracy. Condition: As it related to the institutional portion of HEERF, the College inaccurately reported the quarterly amount drawn from the G5 system and reported amounts in the wrong category (misclassified). Questioned Costs: None. Prevalence: Identified in 2 out of 4 institutional quarterly reports tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The College was not in compliance with reporting requirements for HEERF as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures have been taken.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-004 ? Enrollment Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-004 ? Enrollment Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding No. 2022-002 ? Higher Education Emergency Relief Funds Reporting (Repeat Finding ? 2021-001) Federal Agency: U.S. Department of Education (DOE) Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The College is required to publicly report both timely and accurately on its website aggregate amounts expended for Higher Education Emergency Relief Funds (HEERF) each quarterly reporting period from assistance listings 84.425F Institutional Portion and 84.425M Strengthening Institutions Program. The College must post the quarterly report form no later than 10 days after the end of each calendar quarter publicly on the College?s website on the same page the reports of the College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Additionally, the amounts reported in the quarterly reports must reconcile to the underlying documentation to ensure accuracy. Condition: As it related to the institutional portion of HEERF, the College inaccurately reported the quarterly amount drawn from the G5 system and reported amounts in the wrong category (misclassified). Questioned Costs: None. Prevalence: Identified in 2 out of 4 institutional quarterly reports tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The College was not in compliance with reporting requirements for HEERF as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures have been taken.
Finding No. 2022-003 ? Higher Education Emergency Relief Funds Earmarking Federal Agency: U.S. Department of Education Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The American Rescue Plan created a new requirement that a portion of the HEERF III institutional funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. Condition: There was no evidence that direct outreach was performed during the fiscal year in which the remaining federal fundings under the award were expended. Questioned Costs: None. Prevalence: There was no evidence that direct outreach occurred as required by the program. Effect: Not complying with requirements outlined within applicable grant agreements could result in the DOE withholding payments to the College. Cause: This issue is a result of a lack of proper understanding of applicable requirements. Recommendation: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, we recommend that management implement a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-002 ? Higher Education Emergency Relief Funds Reporting (Repeat Finding ? 2021-001) Federal Agency: U.S. Department of Education (DOE) Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The College is required to publicly report both timely and accurately on its website aggregate amounts expended for Higher Education Emergency Relief Funds (HEERF) each quarterly reporting period from assistance listings 84.425F Institutional Portion and 84.425M Strengthening Institutions Program. The College must post the quarterly report form no later than 10 days after the end of each calendar quarter publicly on the College?s website on the same page the reports of the College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Additionally, the amounts reported in the quarterly reports must reconcile to the underlying documentation to ensure accuracy. Condition: As it related to the institutional portion of HEERF, the College inaccurately reported the quarterly amount drawn from the G5 system and reported amounts in the wrong category (misclassified). Questioned Costs: None. Prevalence: Identified in 2 out of 4 institutional quarterly reports tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The College was not in compliance with reporting requirements for HEERF as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures have been taken.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.