Finding Number: 2022-001
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-002
Material Weakness and Material Noncompliance – Enrollment Reporting
Criteria: Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)).
Federal Direct Student Loans—Changes in student 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 (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)).
Condition: The College did not accurately and timely report certain campus level and program level data as required for the Pell Grant Program and Federal Direct Student Loans programs.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 students tested for campus level and program level reporting, we noted the following:
• Enrollment updates were not posted to NSLDS in a timely manner for all 60 students tested.
• The enrollment statuses for 57 students were not properly updated in NSLDS and did not agree to institutional records.
• The enrollment status effective date for 59 students per NSLDS did not agree with institutional records.
• The student’s program start date for 30 students in NSLDS did not agree with institutional records.
• 2 students which had an incorrect CIP codes assigned in NSLDS.
The College provided NSLDS with monthly student roster batch updates; however, we noted there were unresolved errors in these batch updates for all months in fiscal year 2022.
Cause and Effect: The College did not have a process in place to ensure all student status changes and required student information was accurately and timely reported to NSLDS. The College did not have internal controls in place to ensure all roster reporting errors in NSLDS were appropriately resolved. The unresolved errors resulted in student information not being posted to NSLDS.
Recommendation: The College should implement controls and processes to ensure that all required campus level and program level information is reported accurately and timely to NSLDS.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-001
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-002
Material Weakness and Material Noncompliance – Enrollment Reporting
Criteria: Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)).
Federal Direct Student Loans—Changes in student 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 (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)).
Condition: The College did not accurately and timely report certain campus level and program level data as required for the Pell Grant Program and Federal Direct Student Loans programs.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 students tested for campus level and program level reporting, we noted the following:
• Enrollment updates were not posted to NSLDS in a timely manner for all 60 students tested.
• The enrollment statuses for 57 students were not properly updated in NSLDS and did not agree to institutional records.
• The enrollment status effective date for 59 students per NSLDS did not agree with institutional records.
• The student’s program start date for 30 students in NSLDS did not agree with institutional records.
• 2 students which had an incorrect CIP codes assigned in NSLDS.
The College provided NSLDS with monthly student roster batch updates; however, we noted there were unresolved errors in these batch updates for all months in fiscal year 2022.
Cause and Effect: The College did not have a process in place to ensure all student status changes and required student information was accurately and timely reported to NSLDS. The College did not have internal controls in place to ensure all roster reporting errors in NSLDS were appropriately resolved. The unresolved errors resulted in student information not being posted to NSLDS.
Recommendation: The College should implement controls and processes to ensure that all required campus level and program level information is reported accurately and timely to NSLDS.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-002
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268, 84.007
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-001
Material Weakness and Material Noncompliance – Return of Title IV
Criteria: Federal regulation 34 CFR 668.22 establishes the treatment of Title IV funds when a student withdraws. The regulations establish the required timeframe for identification of students that are no longer attending and the subsequent return of any unearned aid by the College. Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Furthermore, federal regulation 34 CFR 668.22(j)(2) establishes that an institution that is not required to take attendance, must determine the withdrawal date for a student that withdraws without providing notification to the institution, no later than 30 days after the earlier of the – i.) payment period or period of enrollment, ii.) academic year in which the student withdrew; or iii.) educational program from which the student withdrew.
Condition: In testing, we identified a total of 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22. It was noted that the date of determination of withdrawal for 21 of these students were not made within 30 days of the end of the period of enrollment, as required by 34 CFR 668.22(j)(2). In addition, testing identified 11 more students in which the date of determination of withdrawal was timely, however returns were not made to the U.S. Department of Education within 45 days of the date of determination as required by 34 CFR 668.22.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 student withdrawals tested for proper return of Title IV funds, we identified 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22.
Cause and Effect: The exceptions identified in our testing were primarily due to delays in identifying students that unofficially withdrew. The College’s internal control procedures failed to ensure these students were identified and funds returned within the required timelines.
Recommendation: We recommend that the College implement internal controls to ensure all returns of Title IV funds are made to the Department of Education within the required time frame.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-002
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268, 84.007
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-001
Material Weakness and Material Noncompliance – Return of Title IV
Criteria: Federal regulation 34 CFR 668.22 establishes the treatment of Title IV funds when a student withdraws. The regulations establish the required timeframe for identification of students that are no longer attending and the subsequent return of any unearned aid by the College. Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Furthermore, federal regulation 34 CFR 668.22(j)(2) establishes that an institution that is not required to take attendance, must determine the withdrawal date for a student that withdraws without providing notification to the institution, no later than 30 days after the earlier of the – i.) payment period or period of enrollment, ii.) academic year in which the student withdrew; or iii.) educational program from which the student withdrew.
Condition: In testing, we identified a total of 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22. It was noted that the date of determination of withdrawal for 21 of these students were not made within 30 days of the end of the period of enrollment, as required by 34 CFR 668.22(j)(2). In addition, testing identified 11 more students in which the date of determination of withdrawal was timely, however returns were not made to the U.S. Department of Education within 45 days of the date of determination as required by 34 CFR 668.22.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 student withdrawals tested for proper return of Title IV funds, we identified 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22.
Cause and Effect: The exceptions identified in our testing were primarily due to delays in identifying students that unofficially withdrew. The College’s internal control procedures failed to ensure these students were identified and funds returned within the required timelines.
Recommendation: We recommend that the College implement internal controls to ensure all returns of Title IV funds are made to the Department of Education within the required time frame.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-002
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268, 84.007
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-001
Material Weakness and Material Noncompliance – Return of Title IV
Criteria: Federal regulation 34 CFR 668.22 establishes the treatment of Title IV funds when a student withdraws. The regulations establish the required timeframe for identification of students that are no longer attending and the subsequent return of any unearned aid by the College. Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Furthermore, federal regulation 34 CFR 668.22(j)(2) establishes that an institution that is not required to take attendance, must determine the withdrawal date for a student that withdraws without providing notification to the institution, no later than 30 days after the earlier of the – i.) payment period or period of enrollment, ii.) academic year in which the student withdrew; or iii.) educational program from which the student withdrew.
Condition: In testing, we identified a total of 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22. It was noted that the date of determination of withdrawal for 21 of these students were not made within 30 days of the end of the period of enrollment, as required by 34 CFR 668.22(j)(2). In addition, testing identified 11 more students in which the date of determination of withdrawal was timely, however returns were not made to the U.S. Department of Education within 45 days of the date of determination as required by 34 CFR 668.22.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 student withdrawals tested for proper return of Title IV funds, we identified 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22.
Cause and Effect: The exceptions identified in our testing were primarily due to delays in identifying students that unofficially withdrew. The College’s internal control procedures failed to ensure these students were identified and funds returned within the required timelines.
Recommendation: We recommend that the College implement internal controls to ensure all returns of Title IV funds are made to the Department of Education within the required time frame.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-001
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-002
Material Weakness and Material Noncompliance – Enrollment Reporting
Criteria: Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)).
Federal Direct Student Loans—Changes in student 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 (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)).
Condition: The College did not accurately and timely report certain campus level and program level data as required for the Pell Grant Program and Federal Direct Student Loans programs.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 students tested for campus level and program level reporting, we noted the following:
• Enrollment updates were not posted to NSLDS in a timely manner for all 60 students tested.
• The enrollment statuses for 57 students were not properly updated in NSLDS and did not agree to institutional records.
• The enrollment status effective date for 59 students per NSLDS did not agree with institutional records.
• The student’s program start date for 30 students in NSLDS did not agree with institutional records.
• 2 students which had an incorrect CIP codes assigned in NSLDS.
The College provided NSLDS with monthly student roster batch updates; however, we noted there were unresolved errors in these batch updates for all months in fiscal year 2022.
Cause and Effect: The College did not have a process in place to ensure all student status changes and required student information was accurately and timely reported to NSLDS. The College did not have internal controls in place to ensure all roster reporting errors in NSLDS were appropriately resolved. The unresolved errors resulted in student information not being posted to NSLDS.
Recommendation: The College should implement controls and processes to ensure that all required campus level and program level information is reported accurately and timely to NSLDS.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-001
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-002
Material Weakness and Material Noncompliance – Enrollment Reporting
Criteria: Federal Pell Grant Program: An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR Section 690.83(b)(2)).
Federal Direct Student Loans—Changes in student 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 (SSCR) sent to the NSLDS within 60 days of the status change (34 CFR Section 685.309(b)).
Condition: The College did not accurately and timely report certain campus level and program level data as required for the Pell Grant Program and Federal Direct Student Loans programs.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 students tested for campus level and program level reporting, we noted the following:
• Enrollment updates were not posted to NSLDS in a timely manner for all 60 students tested.
• The enrollment statuses for 57 students were not properly updated in NSLDS and did not agree to institutional records.
• The enrollment status effective date for 59 students per NSLDS did not agree with institutional records.
• The student’s program start date for 30 students in NSLDS did not agree with institutional records.
• 2 students which had an incorrect CIP codes assigned in NSLDS.
The College provided NSLDS with monthly student roster batch updates; however, we noted there were unresolved errors in these batch updates for all months in fiscal year 2022.
Cause and Effect: The College did not have a process in place to ensure all student status changes and required student information was accurately and timely reported to NSLDS. The College did not have internal controls in place to ensure all roster reporting errors in NSLDS were appropriately resolved. The unresolved errors resulted in student information not being posted to NSLDS.
Recommendation: The College should implement controls and processes to ensure that all required campus level and program level information is reported accurately and timely to NSLDS.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-002
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268, 84.007
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-001
Material Weakness and Material Noncompliance – Return of Title IV
Criteria: Federal regulation 34 CFR 668.22 establishes the treatment of Title IV funds when a student withdraws. The regulations establish the required timeframe for identification of students that are no longer attending and the subsequent return of any unearned aid by the College. Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Furthermore, federal regulation 34 CFR 668.22(j)(2) establishes that an institution that is not required to take attendance, must determine the withdrawal date for a student that withdraws without providing notification to the institution, no later than 30 days after the earlier of the – i.) payment period or period of enrollment, ii.) academic year in which the student withdrew; or iii.) educational program from which the student withdrew.
Condition: In testing, we identified a total of 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22. It was noted that the date of determination of withdrawal for 21 of these students were not made within 30 days of the end of the period of enrollment, as required by 34 CFR 668.22(j)(2). In addition, testing identified 11 more students in which the date of determination of withdrawal was timely, however returns were not made to the U.S. Department of Education within 45 days of the date of determination as required by 34 CFR 668.22.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 student withdrawals tested for proper return of Title IV funds, we identified 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22.
Cause and Effect: The exceptions identified in our testing were primarily due to delays in identifying students that unofficially withdrew. The College’s internal control procedures failed to ensure these students were identified and funds returned within the required timelines.
Recommendation: We recommend that the College implement internal controls to ensure all returns of Title IV funds are made to the Department of Education within the required time frame.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-002
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268, 84.007
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-001
Material Weakness and Material Noncompliance – Return of Title IV
Criteria: Federal regulation 34 CFR 668.22 establishes the treatment of Title IV funds when a student withdraws. The regulations establish the required timeframe for identification of students that are no longer attending and the subsequent return of any unearned aid by the College. Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Furthermore, federal regulation 34 CFR 668.22(j)(2) establishes that an institution that is not required to take attendance, must determine the withdrawal date for a student that withdraws without providing notification to the institution, no later than 30 days after the earlier of the – i.) payment period or period of enrollment, ii.) academic year in which the student withdrew; or iii.) educational program from which the student withdrew.
Condition: In testing, we identified a total of 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22. It was noted that the date of determination of withdrawal for 21 of these students were not made within 30 days of the end of the period of enrollment, as required by 34 CFR 668.22(j)(2). In addition, testing identified 11 more students in which the date of determination of withdrawal was timely, however returns were not made to the U.S. Department of Education within 45 days of the date of determination as required by 34 CFR 668.22.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 student withdrawals tested for proper return of Title IV funds, we identified 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22.
Cause and Effect: The exceptions identified in our testing were primarily due to delays in identifying students that unofficially withdrew. The College’s internal control procedures failed to ensure these students were identified and funds returned within the required timelines.
Recommendation: We recommend that the College implement internal controls to ensure all returns of Title IV funds are made to the Department of Education within the required time frame.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Finding Number: 2022-002
Federal Program: Student Financial Assistance Cluster
Federal Award Identification Number and Year: N/A
Assistance Listing Number (ALN): 84.063, 84.268, 84.007
Federal Awarding Agency: U.S. Department of Education
Pass-through Entity: None
Repeat Finding: Yes
Prior Audit Finding Number: 2021-001
Material Weakness and Material Noncompliance – Return of Title IV
Criteria: Federal regulation 34 CFR 668.22 establishes the treatment of Title IV funds when a student withdraws. The regulations establish the required timeframe for identification of students that are no longer attending and the subsequent return of any unearned aid by the College. Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Furthermore, federal regulation 34 CFR 668.22(j)(2) establishes that an institution that is not required to take attendance, must determine the withdrawal date for a student that withdraws without providing notification to the institution, no later than 30 days after the earlier of the – i.) payment period or period of enrollment, ii.) academic year in which the student withdrew; or iii.) educational program from which the student withdrew.
Condition: In testing, we identified a total of 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22. It was noted that the date of determination of withdrawal for 21 of these students were not made within 30 days of the end of the period of enrollment, as required by 34 CFR 668.22(j)(2). In addition, testing identified 11 more students in which the date of determination of withdrawal was timely, however returns were not made to the U.S. Department of Education within 45 days of the date of determination as required by 34 CFR 668.22.
Questioned Costs: None.
Identification of How Questioned Costs Were Computed: N/A
Context: Of the 60 student withdrawals tested for proper return of Title IV funds, we identified 32 returns that were not made to the U.S. Department of Education within the timelines required by 34 CFR 668.22.
Cause and Effect: The exceptions identified in our testing were primarily due to delays in identifying students that unofficially withdrew. The College’s internal control procedures failed to ensure these students were identified and funds returned within the required timelines.
Recommendation: We recommend that the College implement internal controls to ensure all returns of Title IV funds are made to the Department of Education within the required time frame.
Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.