2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-002 Procurement Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425F Award Period: July 1, 2021 through June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations section 215.44 states written selection procedures require solicitations for goods or services incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured, identify all requirements for the material, product, or service to be procured, identify all requirements that the offerors must fulfill, and include all other factors to be used in evaluating bids or proposals. In addition, per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: During our testing, we noted the College did not have properly documented procurement regulations that met the federal requirements. We were unable to verify any procurement methods used for the vendor tested. In addition, during our testing, we noted for one out of the one vendors over $25,000 tested, there was not documented suspension and debarment procedures. Questioned costs: None Context: The College did not have documented procurement procedures or procedures in place to verify vendors had not been suspended or debarred. They were not following procurement requirements under Uniform Guidance. Cause: The College was not aware of the requirements of the Uniform Guidance. Effect: The lack of documented procurement regulations and policies over these compliance requirements provides an opportunity for noncompliance. In addition, the College could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the College document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Views of responsible officials: There is no disagreement with the audit finding.
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-003: National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the change in status was reported outside the 60 day window for 2 out of the 40 students tested. In addition, the enrollment status reported to NSLDS did not match the student's transcript for 1 out of the 40 students tested. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure accuracy of NSLDS reporting. Cause: The College's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2021-001 Auditors? Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of Responsible Officials: No Disagreement
2022-002 Procurement Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425F Award Period: July 1, 2021 through June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations section 215.44 states written selection procedures require solicitations for goods or services incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured, identify all requirements for the material, product, or service to be procured, identify all requirements that the offerors must fulfill, and include all other factors to be used in evaluating bids or proposals. In addition, per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: During our testing, we noted the College did not have properly documented procurement regulations that met the federal requirements. We were unable to verify any procurement methods used for the vendor tested. In addition, during our testing, we noted for one out of the one vendors over $25,000 tested, there was not documented suspension and debarment procedures. Questioned costs: None Context: The College did not have documented procurement procedures or procedures in place to verify vendors had not been suspended or debarred. They were not following procurement requirements under Uniform Guidance. Cause: The College was not aware of the requirements of the Uniform Guidance. Effect: The lack of documented procurement regulations and policies over these compliance requirements provides an opportunity for noncompliance. In addition, the College could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the College document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Views of responsible officials: There is no disagreement with the audit finding.