FAC Explorer

Audit 303193

FY End
2023-06-30
Total Expended
$7.09M
Findings
6
Programs
5
Organization: Rosemont College of the Holy Child Jesus (PA)
Year: 2023 Accepted: 2024-04-10
Auditor: Baker Tilly US LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
392907 2023-001 Material Weakness - N
392908 2023-002 Significant Deficiency - E
392909 2023-003 Significant Deficiency - N
969349 2023-001 Material Weakness - N
969350 2023-002 Significant Deficiency - E
969351 2023-003 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $5.92M Yes 3
84.063 Federal Pell Grant Program $922,017 Yes 0
84.038 Federal Perkins Loan Program $146,125 Yes 0
84.033 Federal Work-Study Program $50,646 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $50,000 Yes 0

Contacts

Name Title Type
FUPUKB23DQB6 Charles Steinmetz Auditee
6105272593 Andrea Caladie Auditor
No contacts on file

Notes to SEFA

Title: 1. Basis of Presentation Accounting Policies: The accompanying Schedule includes the federal grant transactions of the College recorded on the accrual basis of accounting. In certain programs, the expenditures reported in the basic financial statements may differ from the expenditures reported in the Schedule due to program expenditures exceeding grant or contract budget limitations which are not reported as expenditures in the Schedule. De Minimis Rate Used: N Rate Explanation: The College has not elected to use the 10% de minimis indirect cost rate for federal grants under Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The Schedule presents only a selected portion of the activities of the College. It is not intended to and does not; present either the financial position, changes in activities, or cash flows of the College.
Title: 2. Summary of Significant Accounting Policies Accounting Policies: The accompanying Schedule includes the federal grant transactions of the College recorded on the accrual basis of accounting. In certain programs, the expenditures reported in the basic financial statements may differ from the expenditures reported in the Schedule due to program expenditures exceeding grant or contract budget limitations which are not reported as expenditures in the Schedule. De Minimis Rate Used: N Rate Explanation: The College has not elected to use the 10% de minimis indirect cost rate for federal grants under Uniform Guidance. The accompanying Schedule includes the federal grant transactions of the College recorded on the accrual basis of accounting. In certain programs, the expenditures reported in the basic financial statements may differ from the expenditures reported in the Schedule due to program expenditures exceeding grant or contract budget limitations which are not reported as expenditures in the Schedule.
Title: 3. Indirect Cost Rate Accounting Policies: The accompanying Schedule includes the federal grant transactions of the College recorded on the accrual basis of accounting. In certain programs, the expenditures reported in the basic financial statements may differ from the expenditures reported in the Schedule due to program expenditures exceeding grant or contract budget limitations which are not reported as expenditures in the Schedule. De Minimis Rate Used: N Rate Explanation: The College has not elected to use the 10% de minimis indirect cost rate for federal grants under Uniform Guidance. The College has not elected to use the 10% de minimis indirect cost rate for federal grants under Uniform Guidance.
Title: 4. Federal Student Loan Program Accounting Policies: The accompanying Schedule includes the federal grant transactions of the College recorded on the accrual basis of accounting. In certain programs, the expenditures reported in the basic financial statements may differ from the expenditures reported in the Schedule due to program expenditures exceeding grant or contract budget limitations which are not reported as expenditures in the Schedule. De Minimis Rate Used: N Rate Explanation: The College has not elected to use the 10% de minimis indirect cost rate for federal grants under Uniform Guidance. The College administers the Federal Perkins Loan Program, and balances and transactions relating to this program are included in the College's financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedule. The total loans outstanding under the Federal Perkins Loan Program at June 30, 2023 were $145,055.

Finding Details

Finding 2023-001
Finding 2023-001: Enrollment Reporting - Material Weakness ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Condition: For 3 withdrawn students, the College erroneously reported the effective date of the withdrawal. For 2 students in a 5-year program, which included a bachelor's and master's program, the College did not report the student's graduation date from the bachelor's degree program and utilized the start date of the bachelor's degree program as the start date of the master's program, resulting in inaccurate reporting. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of the withdrawn students to be human error. The College noted the inaccurate reporting of the students in the 5-year program to be an issue with their reporting policy in place for this particular program and will update the policy moving forward. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Currently, the College marks students withdrawn on the date the withdrawal is officially processed in the system, indicating their last date of attendance. The withdrawal policy will be updated to indicate that the withdraw date to be reported for all students withdrawing at either the program or campus level should be processed as the "last date of attendance". In the case of the 5- year program (4+1 internally), we currently do not officially "enroll" a student into the master's program until their bachelor's degree is conferred. The official admit date will be updated to reflect the term a student enters the master's program officially, which will begin after the conferral of their bachelor's degree. Our policy and processes for the 4+1 program will be updated to reflect this change.
Finding 2023-002
Finding 2023-002: Eligibility - Satisfactory Academic Progress - Significant Deficiency ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: To begin and to continue to participate in any Title IV, HEA program, an institution shall demonstrate to the Secretary that the institution is capable of adequately administering that program under each of the standards established under 34 CFR 668.16. One of these standards states that for purposes of determining student eligibility for assistance under a title IV, HEA program, the institution must establish, publish, and apply reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory academic progress in his or her educational program. Condition: Of the 40 students tested for eligibility, 7 students did not meet satisfactory academic progress. For 6 of those students, the College was not able to provide the academic probation warning or Academic Action Plan that was sent to these students in line with the College's policy. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: If the College is not following their policies and procedures for determining student eligibility of Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to continue participating in the Title IV program. Questioned Costs: None. Recommendation: It is recommended that the College designate an employee within the financial aid department to be responsible for monitoring academic progress and following the procedures stated within the College's Academic Progress Policy when a student does not meet the minimum standards. Management Response: When SAP is run in the spring, students will be notified of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
Finding 2023-003
Finding 2023-003: Return of Title IV Funds – Significant Deficiency ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: For one student selected for testing, the return of Title IV funding was not returned within 45 days of the date that it was determined that the student withdrew. For one student tested, the withdrawal date utilized by the College was inaccurate. The College originally determined that the student had completed 60% of the semester and a refund was not required. However, a return was required based on the student's actual withdrawal date. The College did ultimately return the funds. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The amounts refunded to the Department of Education may be incorrect. The College was also in possession of funds belonging to the federal government longer than allowed. Questioned Costs: $4,675 Context: There were a total of 19 students who withdrew during the year that received Title IV aid. There was only one student that the College determined to require a return of Title IV funds. There was also 1 student who was noted to not have a return of funds who actually did require a return of funds based on testing, resulting in questioned costs. The sample was not considered statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
Finding 2023-001
Finding 2023-001: Enrollment Reporting - Material Weakness ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Condition: For 3 withdrawn students, the College erroneously reported the effective date of the withdrawal. For 2 students in a 5-year program, which included a bachelor's and master's program, the College did not report the student's graduation date from the bachelor's degree program and utilized the start date of the bachelor's degree program as the start date of the master's program, resulting in inaccurate reporting. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of the withdrawn students to be human error. The College noted the inaccurate reporting of the students in the 5-year program to be an issue with their reporting policy in place for this particular program and will update the policy moving forward. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Currently, the College marks students withdrawn on the date the withdrawal is officially processed in the system, indicating their last date of attendance. The withdrawal policy will be updated to indicate that the withdraw date to be reported for all students withdrawing at either the program or campus level should be processed as the "last date of attendance". In the case of the 5- year program (4+1 internally), we currently do not officially "enroll" a student into the master's program until their bachelor's degree is conferred. The official admit date will be updated to reflect the term a student enters the master's program officially, which will begin after the conferral of their bachelor's degree. Our policy and processes for the 4+1 program will be updated to reflect this change.
Finding 2023-002
Finding 2023-002: Eligibility - Satisfactory Academic Progress - Significant Deficiency ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: To begin and to continue to participate in any Title IV, HEA program, an institution shall demonstrate to the Secretary that the institution is capable of adequately administering that program under each of the standards established under 34 CFR 668.16. One of these standards states that for purposes of determining student eligibility for assistance under a title IV, HEA program, the institution must establish, publish, and apply reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory academic progress in his or her educational program. Condition: Of the 40 students tested for eligibility, 7 students did not meet satisfactory academic progress. For 6 of those students, the College was not able to provide the academic probation warning or Academic Action Plan that was sent to these students in line with the College's policy. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: If the College is not following their policies and procedures for determining student eligibility of Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to continue participating in the Title IV program. Questioned Costs: None. Recommendation: It is recommended that the College designate an employee within the financial aid department to be responsible for monitoring academic progress and following the procedures stated within the College's Academic Progress Policy when a student does not meet the minimum standards. Management Response: When SAP is run in the spring, students will be notified of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
Finding 2023-003
Finding 2023-003: Return of Title IV Funds – Significant Deficiency ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: For one student selected for testing, the return of Title IV funding was not returned within 45 days of the date that it was determined that the student withdrew. For one student tested, the withdrawal date utilized by the College was inaccurate. The College originally determined that the student had completed 60% of the semester and a refund was not required. However, a return was required based on the student's actual withdrawal date. The College did ultimately return the funds. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The amounts refunded to the Department of Education may be incorrect. The College was also in possession of funds belonging to the federal government longer than allowed. Questioned Costs: $4,675 Context: There were a total of 19 students who withdrew during the year that received Title IV aid. There was only one student that the College determined to require a return of Title IV funds. There was also 1 student who was noted to not have a return of funds who actually did require a return of funds based on testing, resulting in questioned costs. The sample was not considered statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.