2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 675.19 (b)(2) notes “The institution must also establish and maintain program and fiscal records that (i) Include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours worked in clock time sequence, or the total hours worked per day…”
Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement.
Statistical sampling was not used in making sample selections.
Questioned Costs: $2,565
Cause and Effect: Without proper review of hours worked, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients are being paid for hours worked that have been certified by the recipients’ supervisor.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 690.83 (b)(2) states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) states “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance.
Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Effect: The College has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans.
Recommendation: We recommend the College continually educate themselves on compliance requirements regarding enrollment reporting and implement controls to help timely and accurately report enrollment statuses.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free Application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.”
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement.
Statistical sampling was not used in making sample selections.
Questioned Costs: $5,252
Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. For the disbursement date, the College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid and implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.
Condition: We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement.
Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid.
Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 675.19 (b)(2) notes “The institution must also establish and maintain program and fiscal records that (i) Include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours worked in clock time sequence, or the total hours worked per day…”
Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement.
Statistical sampling was not used in making sample selections.
Questioned Costs: $2,565
Cause and Effect: Without proper review of hours worked, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients are being paid for hours worked that have been certified by the recipients’ supervisor.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 690.83 (b)(2) states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) states “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance.
Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Effect: The College has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans.
Recommendation: We recommend the College continually educate themselves on compliance requirements regarding enrollment reporting and implement controls to help timely and accurately report enrollment statuses.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free Application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.”
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement.
Statistical sampling was not used in making sample selections.
Questioned Costs: $5,252
Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. For the disbursement date, the College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid and implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023
Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.
Condition: We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement.
Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid.
Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan