Audit 25502

FY End
2022-06-30
Total Expended
$13.80M
Findings
6
Programs
12
Organization: Spring Hill College (AL)
Year: 2022 Accepted: 2023-03-30
Auditor: Wilkins Miller

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
35920 2022-001 Significant Deficiency - N
35921 2022-001 Significant Deficiency - N
35922 2022-002 Significant Deficiency - L
612362 2022-001 Significant Deficiency - N
612363 2022-001 Significant Deficiency - N
612364 2022-002 Significant Deficiency - L

Contacts

Name Title Type
GBWXP7UH5WG2 Heidi Butler Auditee
2513802260 Erin Jones Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: For purposes of the Schedule, expenditures for federal award programs are recognized on the accrual basis of accounting. Expenditures for federal student financial assistance programs include Pell program grants to students, FSEOG program grants to students, FWS program earnings, TEACH program grants to students, HRSA program grants to students, and administrative cost allowances where applicable. Additionally, the value of the beginning of the year balance of previous Perkins loans are included as federal award expenditures. Finally, the value of Federal Direct Student Loans processed in the current year are included as federal award expenditures. From time to time, the College is the sub-recipient of federal funds that are reported as expenditures and listed as federal pass-through (FPT) funds. Federal awards other than those indicated as pass-through are considered direct. De Minimis Rate Used: Both Rate Explanation: Except for ALN 45.129, the College has not elected to use the 10 percent de minimis cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) summarizes the federal expenditures of Spring Hill College (the College) under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The amounts reported as federal expenditures were obtained from the Colleges general ledger. Because the Schedule presents only a selected portion of the operations of the College, they are not intended to and do not represent its financial position, the changes in its net assets, or its cash flows.For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the College and agencies and departments of the federal government and all sub-awards to the College by nonfederal organizations pursuant to federal grants, contracts, and similar grants.Student financial assistance includes certain awards to provide financial assistance to students, primarily under the Federal Work-Study (FWS), Federal Pell Grant (Pell), Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Direct Student Loans (FDL), Federal Perkins Loan (Perkins), Teacher Education Assistance for College and Higher Education Grant (TEACH), and Scholarships for Health Professions Students from Disadvantaged Backgrounds (HRSA) programs. On March 27, 2020, Congress passed the Coronavirus Aid, Relief, and Economic Act (CARES Act) in response to the coronavirus pandemic (COVID-19). This allowed the Office of Postsecondary Education to receive $14 billion in relief known as the Higher Education Emergency Relief Fund (HEERF). The HEERF grant funds were distributed for the purpose of responding to COVID-19. On March 11, 2021, HEERF III was authorized by the American Rescue Plan (ARP), Public Law 117-2, providing support to institutions of higher education to serve students to ensure learning continues during the COVID-19 pandemic. The ARP HEERF III funds require that 50% of an institution's funds be spent on student grants. The allowable uses of funds are nearly identical to the CRRSA HEERF II funding. The initial installment of the HEERF III grant received during the year ended June 30, 2022 of $1,751,290 was designated for grants directly to students. The second installment of the HEERF III grant received during the year ended June 30, 2022 was $1,775,355. Consistent with Section 314(a)(1) of the CRRSAA, $381,207 was used for virtual learning, $100,000 offset rental income that was lost, and $36,643 COVID-19 testing and COVID-19 related supplies. The remaining $1,257,505 was used for the offset of loss of revenue due to COVID-19.
Title: FEDERAL STUDENT LOAN PROGRAMS Accounting Policies: For purposes of the Schedule, expenditures for federal award programs are recognized on the accrual basis of accounting. Expenditures for federal student financial assistance programs include Pell program grants to students, FSEOG program grants to students, FWS program earnings, TEACH program grants to students, HRSA program grants to students, and administrative cost allowances where applicable. Additionally, the value of the beginning of the year balance of previous Perkins loans are included as federal award expenditures. Finally, the value of Federal Direct Student Loans processed in the current year are included as federal award expenditures. From time to time, the College is the sub-recipient of federal funds that are reported as expenditures and listed as federal pass-through (FPT) funds. Federal awards other than those indicated as pass-through are considered direct. De Minimis Rate Used: Both Rate Explanation: Except for ALN 45.129, the College has not elected to use the 10 percent de minimis cost rate allowed under the Uniform Guidance. The Federal Perkins Loan Program (ALN 84.038) is administered directly by the College, and balances and transactions relating to this program are included in the Colleges financial statements. The balances of loans outstanding at June 30, 2022, and funds advanced by the College to eligible students during the year ended June 30, 2022, under this federal student loan program can be summarized as follows:The College is responsible only for the performance of certain administrative duties with respect to the Federal Direct Student Loans Program. Accordingly, balances and transactions relating to this loan program are not included in the Colleges general purpose financial statements. Therefore, it is not practical to determine the balance of such loans outstanding to students and former students of the College at June 30, 2022. During the year ended June 30, 2022, the College processed $6,233,916 of new loans under the Federal Direct Student Loans Program (ALN 84.268).
Title: RECONCILIATION OF THE SEFA TO THE STATEMENT OF ACTIVITIES Accounting Policies: For purposes of the Schedule, expenditures for federal award programs are recognized on the accrual basis of accounting. Expenditures for federal student financial assistance programs include Pell program grants to students, FSEOG program grants to students, FWS program earnings, TEACH program grants to students, HRSA program grants to students, and administrative cost allowances where applicable. Additionally, the value of the beginning of the year balance of previous Perkins loans are included as federal award expenditures. Finally, the value of Federal Direct Student Loans processed in the current year are included as federal award expenditures. From time to time, the College is the sub-recipient of federal funds that are reported as expenditures and listed as federal pass-through (FPT) funds. Federal awards other than those indicated as pass-through are considered direct. De Minimis Rate Used: Both Rate Explanation: Except for ALN 45.129, the College has not elected to use the 10 percent de minimis cost rate allowed under the Uniform Guidance. The majority of expenditures as shown on the Schedule for the year ended June 30, 2022 are excluded from the Statement of Activities in the College's basic financial statements as a result of the following financial statement presentations. Perkins disbursements are recorded to "Loans receivable - students, net" on the Statement of Financial Position in the College's basic financial statements. Draws for FSEOG, Pell, Federal Direct Loans, TEACH, and HRSA reduce student receivables. Draws for FWS are netted with the associated wages paid. The initial installment of the HEERF III funds were distributed directly to students and are reported in "Student aid" on the Statement of Activities. The second installment of the HEERF III and other programs are reported in the various operating expenses on the Statement of Activities.

Finding Details

Condition: There was lack of documentation related to disbursement notices and exit counseling for nine out of thirty-four students tested. Criteria: According to ?668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to ?682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268 and ALN 84.379, it was determined that documenation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.
Condition: There was lack of documentation related to disbursement notices and exit counseling for nine out of thirty-four students tested. Criteria: According to ?668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to ?682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268 and ALN 84.379, it was determined that documenation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.
Condition: There was no quarterly reporting for the fourth quarter of 2021 for the Institutional Portion of the HEERF III grant. Criteria: Institutions must complete and post on their websites an institutional reporting form. This form includes reporting categories on mental health spending, HEERF (a)(2) construction flexibilities, and lost revenue. This form must be conspicuously posted on the institutions? website no later than 10 days after the calendar quarter (January 10, April 10, July 10, and October 10) as long as the institution?s HEERF grant is active. Cause: The College did not prepare or post the quarterly report for the Institutional Portion of the HEERF III grant for the fourth quarter of 2021. Context: During the compliance audit testing of ALN 84.425F, it was determined that the College did not fully adhere to the quarterly reporting compliance requirement for the Institutional Portion of the HEERF III grant. Recommendation: We recommend compliance with all reporting requirements for the HEERF III grant. View of Responsible Officials and Planned Corrective Action: The report indicating institutional dollars spent for fourth quarter of 2021 has been posted to the College's website as of March 29, 2023. Going forward all reports will be submitted and posted in a timely manner.
Condition: There was lack of documentation related to disbursement notices and exit counseling for nine out of thirty-four students tested. Criteria: According to ?668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to ?682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268 and ALN 84.379, it was determined that documenation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.
Condition: There was lack of documentation related to disbursement notices and exit counseling for nine out of thirty-four students tested. Criteria: According to ?668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to ?682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268 and ALN 84.379, it was determined that documenation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.
Condition: There was no quarterly reporting for the fourth quarter of 2021 for the Institutional Portion of the HEERF III grant. Criteria: Institutions must complete and post on their websites an institutional reporting form. This form includes reporting categories on mental health spending, HEERF (a)(2) construction flexibilities, and lost revenue. This form must be conspicuously posted on the institutions? website no later than 10 days after the calendar quarter (January 10, April 10, July 10, and October 10) as long as the institution?s HEERF grant is active. Cause: The College did not prepare or post the quarterly report for the Institutional Portion of the HEERF III grant for the fourth quarter of 2021. Context: During the compliance audit testing of ALN 84.425F, it was determined that the College did not fully adhere to the quarterly reporting compliance requirement for the Institutional Portion of the HEERF III grant. Recommendation: We recommend compliance with all reporting requirements for the HEERF III grant. View of Responsible Officials and Planned Corrective Action: The report indicating institutional dollars spent for fourth quarter of 2021 has been posted to the College's website as of March 29, 2023. Going forward all reports will be submitted and posted in a timely manner.