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.