Audit 289882

FY End
2023-06-30
Total Expended
$10.07M
Findings
24
Programs
16
Year: 2023 Accepted: 2024-02-12
Auditor: Crowe LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
366822 2023-001 Material Weakness Yes L
366823 2023-002 Material Weakness - N
366824 2023-003 Significant Deficiency - N
366825 2023-001 Material Weakness Yes L
366826 2023-002 Material Weakness - N
366827 2023-003 Significant Deficiency - N
366828 2023-001 Material Weakness Yes L
366829 2023-002 Material Weakness - N
366830 2023-003 Significant Deficiency - N
366831 2023-001 Material Weakness Yes L
366832 2023-002 Material Weakness - N
366833 2023-003 Significant Deficiency - N
943264 2023-001 Material Weakness Yes L
943265 2023-002 Material Weakness - N
943266 2023-003 Significant Deficiency - N
943267 2023-001 Material Weakness Yes L
943268 2023-002 Material Weakness - N
943269 2023-003 Significant Deficiency - N
943270 2023-001 Material Weakness Yes L
943271 2023-002 Material Weakness - N
943272 2023-003 Significant Deficiency - N
943273 2023-001 Material Weakness Yes L
943274 2023-002 Material Weakness - N
943275 2023-003 Significant Deficiency - N

Contacts

Name Title Type
J5E5CM8RN125 Tyhani Hill Auditee
7085962000 John Weber Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: The accompanying Schedule has been prepared on the accrual basis of accounting. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of students’ FSEOG program grants, FWS program earnings, and administrative cost allowances, where applicable. Expenditures for other federal awards of the College are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) summarizes the federal awards expended by South Suburban College-Community College District No. 510 (the College) for the year ended June 30, 2023. For the purposes of the Schedule, federal awards include all grants, contracts, loans, and loan guarantee agreements entered into directly between the College and agencies and departments of the federal government. The College has classified all awards into major and nonmajor programs in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Major programs include the following: Student Financial Aid Program Cluster – Includes certain awards to provide financial assistance to students, primarily under the Federal Pell Grant (Pell), Federal Supplementary Educational Opportunity Grant (FSEOG), and Federal Work-Study (FWS) programs of the Department of Education. Coronavirus Aid, Relief and Economic Security Act Grant – Includes awards to provide financial assistance to students and institutions adversely impacted by the COVID-19 pandemic.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying Schedule has been prepared on the accrual basis of accounting. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of students’ FSEOG program grants, FWS program earnings, and administrative cost allowances, where applicable. Expenditures for other federal awards of the College are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule has been prepared on the accrual basis of accounting. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of students’ FSEOG program grants, FWS program earnings, and administrative cost allowances, where applicable. Expenditures for other federal awards of the College are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. The College has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: MAJOR PROGRAMS Accounting Policies: The accompanying Schedule has been prepared on the accrual basis of accounting. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of students’ FSEOG program grants, FWS program earnings, and administrative cost allowances, where applicable. Expenditures for other federal awards of the College are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. In accordance with the Uniform Guidance, major programs for the College are individual programs or a cluster of programs determined by using a risk-based analysis. The threshold for distinguishing Type A and Type B programs was $750,000 and $187,500, respectively. Student Financial Aid programs are designated as clusters of programs.
Title: NON-CASH ASSISTANCE Accounting Policies: The accompanying Schedule has been prepared on the accrual basis of accounting. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of students’ FSEOG program grants, FWS program earnings, and administrative cost allowances, where applicable. Expenditures for other federal awards of the College are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The College had no non-cash assistance during the year.
Title: FEDERAL INSURANCE Accounting Policies: The accompanying Schedule has been prepared on the accrual basis of accounting. Expenditures for federal student financial aid programs are recognized as incurred and include Pell program grants to students, the federal share of students’ FSEOG program grants, FWS program earnings, and administrative cost allowances, where applicable. Expenditures for other federal awards of the College are determined using the cost accounting principles and procedures set forth in the Uniform Guidance. Under these cost principles, certain expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The College had no Federal Insurance in force during the year.

Finding Details

FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.