Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)).
Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context There were two errors identified that attributed to this finding:
1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date.
2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days.
Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner.
Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS.
Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process.
Note:
• Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding.
• Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding.
There were no questioned costs associated with the finding.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section.
A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than:
(i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period
(ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1))
Condition - Certain credit balances were not refunded to students within 14 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days.
Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations.
Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days.
Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period.
Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students.
There were no questioned costs associated with the finding
Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)).
Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context There were two errors identified that attributed to this finding:
1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date.
2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days.
Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner.
Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS.
Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process.
Note:
• Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding.
• Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding.
There were no questioned costs associated with the finding.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section.
A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than:
(i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period
(ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1))
Condition - Certain credit balances were not refunded to students within 14 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days.
Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations.
Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days.
Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period.
Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students.
There were no questioned costs associated with the finding
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section.
A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than:
(i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period
(ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1))
Condition - Certain credit balances were not refunded to students within 14 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days.
Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations.
Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days.
Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period.
Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students.
There were no questioned costs associated with the finding
Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants
Federal Award Identification Number and Year - N/A
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F.
Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards.
Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact:
$38,970,352 loan under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect.
Recommendation - The College should implement process to ensure that the SEFA is complete and accurate.
Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)).
Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context There were two errors identified that attributed to this finding:
1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date.
2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days.
Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner.
Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS.
Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process.
Note:
• Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding.
• Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding.
There were no questioned costs associated with the finding.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section.
A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than:
(i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period
(ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1))
Condition - Certain credit balances were not refunded to students within 14 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days.
Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations.
Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days.
Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period.
Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students.
There were no questioned costs associated with the finding
Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)).
Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context There were two errors identified that attributed to this finding:
1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date.
2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days.
Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner.
Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS.
Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process.
Note:
• Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding.
• Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding.
There were no questioned costs associated with the finding.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section.
A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than:
(i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period
(ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1))
Condition - Certain credit balances were not refunded to students within 14 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days.
Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations.
Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days.
Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period.
Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students.
There were no questioned costs associated with the finding
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section.
A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than:
(i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period
(ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1))
Condition - Certain credit balances were not refunded to students within 14 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days.
Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations.
Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days.
Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period.
Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students.
There were no questioned costs associated with the finding
Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants
Federal Award Identification Number and Year - N/A
Pass through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F.
Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards.
Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact:
$38,970,352 loan under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect.
Recommendation - The College should implement process to ensure that the SEFA is complete and accurate.
Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.