Audit 30447

FY End
2022-06-30
Total Expended
$17.63M
Findings
6
Programs
10
Organization: Philander Smith College (AR)
Year: 2022 Accepted: 2023-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
29951 2022-002 Significant Deficiency Yes N
29952 2022-002 Significant Deficiency Yes N
29953 2022-003 Significant Deficiency Yes LN
606393 2022-002 Significant Deficiency Yes N
606394 2022-002 Significant Deficiency Yes N
606395 2022-003 Significant Deficiency Yes LN

Programs

ALN Program Spent Major Findings
84.425 Education Stabilization Fund $5.54M Yes 0
84.268 Federal Direct Student Loans $3.95M - 2
84.031 Higher Education_institutional Aid $3.34M Yes 0
84.063 Federal Pell Grant Program $2.30M - 1
93.558 Temporary Assistance for Needy Families $204,497 - 0
84.007 Federal Supplemental Educational Opportunity Grants $140,469 - 0
84.033 Federal Work-Study Program $45,462 - 0
47.076 Education and Human Resources $38,827 - 0
47.083 Integrative Activities $34,270 - 0
93.680 Medical Student Education $24,914 - 0

Contacts

Name Title Type
KNSZRUCJ3JA4 Latonya Hayes Auditee
5013705341 Patricia Pryor Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of presentation Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable. Awards Passed Through to Subrecipients - There were no awards passed through to subrecipients by the College for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The College has elected not to use the 10 percent de minimum indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of Federal awards (the "Schedule") includes the Federal grant activity of Philander Smith College (the "College") and is presented on the accrual basis of accounting. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the College.
Title: Note 3 - Assistance Listing numbers Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable. Awards Passed Through to Subrecipients - There were no awards passed through to subrecipients by the College for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The College has elected not to use the 10 percent de minimum indirect cost rate as allowed under the Uniform Guidance. All programs included in the Schedule are presented by Federal agency and major subdivision within the Federal agency. Pass-through awards have been presented by pass-through entity and Federal identification number or pass-through entity identification number, when available.
Title: Note 4 - Federal Direct Student Loans Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable. Awards Passed Through to Subrecipients - There were no awards passed through to subrecipients by the College for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The College has elected not to use the 10 percent de minimum indirect cost rate as allowed under the Uniform Guidance. During the year ended June 30, 2022, the College processed $3,946,745 of new loans under the Federal Direct Student Loans program (Federal Assistance Listing No. 84.268). The College is responsible only for the performance of certain administrative duties with respect to the Federal Direct Student Loans program and, accordingly, these loans are not included on the College's financial statements; furthermore, it is not practical to determine the balance of loans outstanding to students and former students of the College under these programs at June 30, 2022.
Title: Note 5 - Federal Perkins Loan Program liquidation Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable. Awards Passed Through to Subrecipients - There were no awards passed through to subrecipients by the College for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The College has elected not to use the 10 percent de minimum indirect cost rate as allowed under the Uniform Guidance. The Federal Perkins Loan Program is administered directly by the College. Balances and transactions relating to this program are included in the College's financial statements. Outstanding loan balances under the Federal Perkins Loan Program are fully reserved as of June 30, 2022. The College no longer participates in the Perkins Loan Program and is in the process of liquidating its Perkins revolving student loan fund and is assigning its Perkins Loan portfolio to the Department of Education.
Title: Note 6 - Higher Education Emergency Relief Fund (AL# 84.425) Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable. Awards Passed Through to Subrecipients - There were no awards passed through to subrecipients by the College for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The College has elected not to use the 10 percent de minimum indirect cost rate as allowed under the Uniform Guidance. The Coronavirus Aid, Recovery, and Economic Security Act created a Higher Education Emergency Relief Fund ("HEERF") to provide financial relief to students and institutions who were impacted by the COVID-19 pandemic. The Coronavirus Response and Relief Supplemental Appropriations Act and the American Rescue Plan provided additional rounds of HEERF (II and III) funding. HEERF funds contained three components: an institutional award, a student aid award, and a strengthening institutions award. The following cumulative amounts have been awarded under HEERF as of June 30, 2022: See notes to the SEFA for Table/Chart. The College expended the following amounts under HEERF during the year ended June 30, 2022: See notes to the SEFA for Table/Chart.

Finding Details

Finding 2022-002 ? Federal Pell Grant, Federal Direct Student Loans ? Federal Student Financial Aid Cluster, CFDA# 84.063, 84.268 Compliance Requirement: Special Tests ? Enrollment Reporting Condition: Student status changes were not reported to the National Student Loan Data System (?NSLDS?) in a timely manner or were not accurately reported. Criteria: Under the Pell grant and ED loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); FFEL, 34 CFR Section 682.610; Direct Loan, 34 CFR Section 685.309). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Cause: The College?s internal controls and processes in place surrounding enrollment reporting need to be strengthened. Context: Out of a population of 20 withdrawn and 146 graduated students, a population of two withdrawn students and the 15 graduated students were selected for testing. The College failed to communicate to NSLDS a change of status in a timely manner in 1 instance and reported 6 students as withdrawn that should have been reported as graduated students. Effect: Changes in enrollment status were not reported timely and accurately. Repeat Finding: This finding was a repeat of Finding 2021-003 in the immediate prior audit. Recommendation: The College should continue to review its processes and procedures over enrollment reporting and implement internal controls over compliance that prevent and detect both a lack of communication of withdrawal changes and an improper communication of enrollment status and effective dates. The College should conduct a retrospective review of its Enrollment Reporting Summary Report (SCHER1) file on the NSLDS website and compare to the Registrar?s records to ensure that previously communicated status changes (and status changes that have not been communicated) are correctly communicated to the Department of Education. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management?s corrective action plan.
Finding 2022-002 ? Federal Pell Grant, Federal Direct Student Loans ? Federal Student Financial Aid Cluster, CFDA# 84.063, 84.268 Compliance Requirement: Special Tests ? Enrollment Reporting Condition: Student status changes were not reported to the National Student Loan Data System (?NSLDS?) in a timely manner or were not accurately reported. Criteria: Under the Pell grant and ED loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); FFEL, 34 CFR Section 682.610; Direct Loan, 34 CFR Section 685.309). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Cause: The College?s internal controls and processes in place surrounding enrollment reporting need to be strengthened. Context: Out of a population of 20 withdrawn and 146 graduated students, a population of two withdrawn students and the 15 graduated students were selected for testing. The College failed to communicate to NSLDS a change of status in a timely manner in 1 instance and reported 6 students as withdrawn that should have been reported as graduated students. Effect: Changes in enrollment status were not reported timely and accurately. Repeat Finding: This finding was a repeat of Finding 2021-003 in the immediate prior audit. Recommendation: The College should continue to review its processes and procedures over enrollment reporting and implement internal controls over compliance that prevent and detect both a lack of communication of withdrawal changes and an improper communication of enrollment status and effective dates. The College should conduct a retrospective review of its Enrollment Reporting Summary Report (SCHER1) file on the NSLDS website and compare to the Registrar?s records to ensure that previously communicated status changes (and status changes that have not been communicated) are correctly communicated to the Department of Education. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management?s corrective action plan.
Finding 2022-003 ? Federal Direct Student Loan ? Federal Student Financial Aid Cluster, CFDA# 84.268 Compliance Requirement: Reporting, Special Tests ? Borrower Data Transmission and Reconciliation Condition: Documentation to support the College?s reconciliation between the School Account Statement (?SAS?) data file and the College?s financial records were performed was not available. Criteria: Each month, the COD provides institutions with a SAS data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Institution?s financial records. Cause: The College?s internal controls and processes in place surrounding borrower data transmission and reconciliations of the SAS data file need to be strengthened. Context: Two monthly reconciliations were selected for testing and documentation to support that the reconciliation was performed was not available. Effect: Incorrect disbursement dates could be reported to COD. Repeat Finding: This finding was a repeat of Finding 2021-004 in the immediate prior audit. Recommendation: The College should maintain documentation evidencing the reconciliation between the SAS data file and the College?s financial records. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management?s corrective action plan.
Finding 2022-002 ? Federal Pell Grant, Federal Direct Student Loans ? Federal Student Financial Aid Cluster, CFDA# 84.063, 84.268 Compliance Requirement: Special Tests ? Enrollment Reporting Condition: Student status changes were not reported to the National Student Loan Data System (?NSLDS?) in a timely manner or were not accurately reported. Criteria: Under the Pell grant and ED loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); FFEL, 34 CFR Section 682.610; Direct Loan, 34 CFR Section 685.309). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Cause: The College?s internal controls and processes in place surrounding enrollment reporting need to be strengthened. Context: Out of a population of 20 withdrawn and 146 graduated students, a population of two withdrawn students and the 15 graduated students were selected for testing. The College failed to communicate to NSLDS a change of status in a timely manner in 1 instance and reported 6 students as withdrawn that should have been reported as graduated students. Effect: Changes in enrollment status were not reported timely and accurately. Repeat Finding: This finding was a repeat of Finding 2021-003 in the immediate prior audit. Recommendation: The College should continue to review its processes and procedures over enrollment reporting and implement internal controls over compliance that prevent and detect both a lack of communication of withdrawal changes and an improper communication of enrollment status and effective dates. The College should conduct a retrospective review of its Enrollment Reporting Summary Report (SCHER1) file on the NSLDS website and compare to the Registrar?s records to ensure that previously communicated status changes (and status changes that have not been communicated) are correctly communicated to the Department of Education. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management?s corrective action plan.
Finding 2022-002 ? Federal Pell Grant, Federal Direct Student Loans ? Federal Student Financial Aid Cluster, CFDA# 84.063, 84.268 Compliance Requirement: Special Tests ? Enrollment Reporting Condition: Student status changes were not reported to the National Student Loan Data System (?NSLDS?) in a timely manner or were not accurately reported. Criteria: Under the Pell grant and ED loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); FFEL, 34 CFR Section 682.610; Direct Loan, 34 CFR Section 685.309). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Cause: The College?s internal controls and processes in place surrounding enrollment reporting need to be strengthened. Context: Out of a population of 20 withdrawn and 146 graduated students, a population of two withdrawn students and the 15 graduated students were selected for testing. The College failed to communicate to NSLDS a change of status in a timely manner in 1 instance and reported 6 students as withdrawn that should have been reported as graduated students. Effect: Changes in enrollment status were not reported timely and accurately. Repeat Finding: This finding was a repeat of Finding 2021-003 in the immediate prior audit. Recommendation: The College should continue to review its processes and procedures over enrollment reporting and implement internal controls over compliance that prevent and detect both a lack of communication of withdrawal changes and an improper communication of enrollment status and effective dates. The College should conduct a retrospective review of its Enrollment Reporting Summary Report (SCHER1) file on the NSLDS website and compare to the Registrar?s records to ensure that previously communicated status changes (and status changes that have not been communicated) are correctly communicated to the Department of Education. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management?s corrective action plan.
Finding 2022-003 ? Federal Direct Student Loan ? Federal Student Financial Aid Cluster, CFDA# 84.268 Compliance Requirement: Reporting, Special Tests ? Borrower Data Transmission and Reconciliation Condition: Documentation to support the College?s reconciliation between the School Account Statement (?SAS?) data file and the College?s financial records were performed was not available. Criteria: Each month, the COD provides institutions with a SAS data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Institution?s financial records. Cause: The College?s internal controls and processes in place surrounding borrower data transmission and reconciliations of the SAS data file need to be strengthened. Context: Two monthly reconciliations were selected for testing and documentation to support that the reconciliation was performed was not available. Effect: Incorrect disbursement dates could be reported to COD. Repeat Finding: This finding was a repeat of Finding 2021-004 in the immediate prior audit. Recommendation: The College should maintain documentation evidencing the reconciliation between the SAS data file and the College?s financial records. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management?s corrective action plan.