2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 009
Federal Agency: U.S. Department of Education
Federal Program Title: HEERF
Assistance Listing Number: 84.425
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020.
Condition: During our testing of the reporting process, we noted:
1. The March 31, 2023, quarterly report did not have proper documentation of expenditures.
2. The June 30, 2023, quarterly report did not have proper documentation of expenditures.
Questioned Costs: None.
Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed.
Cause: The College did not have someone tracking the requirements to ensure that they posted the reporting accurately.
Effect: There was inaccurate reporting on the College’s website.
Repeat Finding: Yes, see finding 2022-007.
Recommendation: We recommend the College establish a review process to ensure accurate submission.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 010
Federal Agency: U.S. Department of Education
Federal Program Title: HEERF
Assistance Listing Number: 84.425F
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires colleges to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward.
Condition: During our testing, we noted that for one of the five disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Also, it was noted that procedures were not properly performed for one of the five disbursements tested for suspension and debarment.
Questioned Costs: None
Context: The College did not have appropriate documentation that met the federal procurement and suspension and debarment requirements.
Cause: The College was unable to locate the support for the procurement and suspension and debarment procedures followed for this specific disbursement.
Effect: The College did not have appropriate documentation that met the federal procurement requirements.
Repeat Finding: Yes, see finding 2022-008.
Recommendation: We recommend that the College review its procurement and suspension and debarment policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 001
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: During our testing, we noted 1 of the 17 students enrollment status per institution's record did not match what was reported to NSLDS. This student also was not enrolled in a program eligible for Title IV aid yet was included in the aid listing and received aid during the year.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate and correct information.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. In addition, students that are enrolled in programs not eligible for title IV aid should not be eligible to receive aid and there is not a safeguard to prevent this from happening.
Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. In addition, students that are not eligible to receive aid may receive aid which can cause title IV aid to not be spent in ways the college is not supposed to spend it.
Repeat Finding: Yes, see finding 2022-002.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations and they review who aid is given to, ensuring only those in title IV eligible programs are receiving aid.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 002
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2022-23 academic year, R2T4 calculations, direct payment of FSA credit balances to students, policy against providing commission based on recruitment or admission activity, and professional judgement.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2022-23 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department as well as limited personnel to have segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2022-003.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
2023 – 003
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student's estimated cost of attendance for the period of enrollment for which the loan is intended less the student's estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower's expected family contribution for that period.
Condition: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Questioned Costs: None
Context: During our testing, we noted 5 instances of a systematic error resulting in students being over-awarded need-based aid (subsidized loans). We also noted 2 of the 40 students tested had an incorrect cost of attendance used during their initial packaging process. However, amount awarded was not affected by this error.
Cause: Management incorrectly awarded these students based on their enrollment status, financial need and cost of attendance.
Effect: Students may be awarded need based aid in excess of their calculated need if the incorrect cost of attendance is used in the need calculation.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 004
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts.
Condition: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education.
Questioned Costs: None
Context: During our testing, we noted that 1 of 40 students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe.
Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 005
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.604 requires that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions.
Condition: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely for 1 of the 40 students tested.
Questioned Costs: None
Context: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Cause: During our testing, we noted the College’s processes and controls did not ensure that exit counseling procedures were completed timely.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 006
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Direct Loan (34 CFR 685.309) funds to a student.
Condition: During our testing, we noted 1 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system.
Questioned Costs: None
Context: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Cause: The College does not have a process in place to accurately report the date of Direct Loan disbursements.
Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat Finding: Yes, see finding 2022-004.
Auditor’s Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 007
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted 1 of the 10 individuals tested had used an improper last date of attendance, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $390
Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a positive impact on the calculation on percent of aid earned and the amount of Title IV aid refunded.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2022-005.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 008
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: No.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
2023 – 009
Federal Agency: U.S. Department of Education
Federal Program Title: HEERF
Assistance Listing Number: 84.425
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020.
Condition: During our testing of the reporting process, we noted:
1. The March 31, 2023, quarterly report did not have proper documentation of expenditures.
2. The June 30, 2023, quarterly report did not have proper documentation of expenditures.
Questioned Costs: None.
Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed.
Cause: The College did not have someone tracking the requirements to ensure that they posted the reporting accurately.
Effect: There was inaccurate reporting on the College’s website.
Repeat Finding: Yes, see finding 2022-007.
Recommendation: We recommend the College establish a review process to ensure accurate submission.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023 – 010
Federal Agency: U.S. Department of Education
Federal Program Title: HEERF
Assistance Listing Number: 84.425F
Award Period: July 1, 2022, to June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires colleges to have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward.
Condition: During our testing, we noted that for one of the five disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Also, it was noted that procedures were not properly performed for one of the five disbursements tested for suspension and debarment.
Questioned Costs: None
Context: The College did not have appropriate documentation that met the federal procurement and suspension and debarment requirements.
Cause: The College was unable to locate the support for the procurement and suspension and debarment procedures followed for this specific disbursement.
Effect: The College did not have appropriate documentation that met the federal procurement requirements.
Repeat Finding: Yes, see finding 2022-008.
Recommendation: We recommend that the College review its procurement and suspension and debarment policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed.
Views of Responsible Officials: There is no disagreement with the audit finding.