Audit 306623

FY End
2022-05-31
Total Expended
$18.12M
Findings
16
Programs
10
Organization: Keystone College (PA)
Year: 2022 Accepted: 2024-05-20

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
397878 2022-003 Significant Deficiency Yes C
397879 2022-004 Significant Deficiency - C
397880 2022-005 Significant Deficiency - L
397881 2022-006 Significant Deficiency Yes N
397882 2022-006 Significant Deficiency Yes N
397883 2022-006 Significant Deficiency Yes N
397884 2022-006 Significant Deficiency Yes N
397885 2022-006 Significant Deficiency Yes N
974320 2022-003 Significant Deficiency Yes C
974321 2022-004 Significant Deficiency - C
974322 2022-005 Significant Deficiency - L
974323 2022-006 Significant Deficiency Yes N
974324 2022-006 Significant Deficiency Yes N
974325 2022-006 Significant Deficiency Yes N
974326 2022-006 Significant Deficiency Yes N
974327 2022-006 Significant Deficiency Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $7.09M Yes 1
84.063 Federal Pell Grant Program $2.66M Yes 2
59.008 Disaster Assistance Loans $2.00M Yes 0
84.038 Federal Perkins Loan $860,032 Yes 1
20.205 Highway Planning and Construction $571,238 - 0
84.425 Education Stabilization Fund $199,039 Yes 1
21.019 Coronavirus Relief Fund $79,498 - 0
84.033 Federal Work-Study Program $45,231 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $43,984 Yes 2
10.558 Child and Adult Care Food Program $32,737 - 0

Contacts

Name Title Type
EVNRN16ZFLK4 John Pullo Auditee
5709458505 Ken Badasarian Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10% de minimis indirect cost rate. The accompanying schedule of expenditures of federal awards (the Schedule) includes federal award activity of Keystone College (the College) under programs of the federal government for the year ended May 31, 2022. The information in 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 (Uniform Guidance). Because this 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: SUBRECIPIENTS Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10% de minimis indirect cost rate. The College did not pass any awards through to subrecipients.
Title: FEDERAL LOAN PROGRAMS Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10% de minimis indirect cost rate. The Federal Perkins Loan Program (84.038) is administered directly by the College, 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. Federal Perkins loans outstanding at May 31, 2022 totaled $837,444. Total loans granted under the Federal Direct Student Loan Program, which were not made by the College but were received by its students, were $7,087,340 for the year ended May 31, 2022. The total outstanding loan balance under the Economic Injury Disaster Loan Program is $2,000,000. The College was awarded an additional $1,850,000 under this program during the year ended May 31, 2022.

Finding Details

Condition: During the year, the College disbursed $43,983 of SEOG funds to students but drew down their entire authorized amount of $123,626 resulting in an overdraw of $79,643. Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education (DOE). Context: A review of the entire population of drawdowns for the Student Financial Aid cluster for the entire year was performed and as such, the sample is statistically valid. Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College was not in compliance with the HCM1 drawdown payment method. Questioned costs: $79,643. Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the HCM payment method. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
Condition: The College did not fully comply with the requirements outlined in the award that requires funds to be disbursed within 3 days of the drawdown from G5. The College follows the cash basis of accounting as described in the footnotes to the schedule of expenditures of federal awards, and during the year, it charged $116,037 prior to drawdown and $83,561 subsequent to drawdown. Criteria: CRRSAA HEERF II and ARP HEERF II require that Institutional Aid Portions should be disbursed within 3 calendar days of the drawdown from G5. Cause: Personnel were not fully aware of the timeframe required for funds to be spend under the award agreement. Effect: The College was not in compliance with the Cash Management compliance requirement. Questioned costs: Not Applicable. Recommendation: The College should take action to ensure staff are trained to be knowledgeable of all requirements under federal awards it receives. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
Condition: It was noted during the audit that the amount of Pell awards granted to students was not accurately reported on the College’s annual Fiscal Operations Report and Application to Participate (FISAP). Criteria: Non-federal entities are required to submit the FISAP electronically, on an annual basis, for its campus-based programs to report expenditures in the previous award year. Cause: The Chief Financial Officer reported the incorrect amount of Pell awards disbursed to students. Effect: Inaccurate report was filed. Questioned costs: Not applicable. Views of Responsible Officials and Planned Corrective Actions: The College should establish a procedure that requires a separate review of the FISAP prior to submission. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: During the year, the College disbursed $43,983 of SEOG funds to students but drew down their entire authorized amount of $123,626 resulting in an overdraw of $79,643. Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education (DOE). Context: A review of the entire population of drawdowns for the Student Financial Aid cluster for the entire year was performed and as such, the sample is statistically valid. Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College was not in compliance with the HCM1 drawdown payment method. Questioned costs: $79,643. Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the HCM payment method. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
Condition: The College did not fully comply with the requirements outlined in the award that requires funds to be disbursed within 3 days of the drawdown from G5. The College follows the cash basis of accounting as described in the footnotes to the schedule of expenditures of federal awards, and during the year, it charged $116,037 prior to drawdown and $83,561 subsequent to drawdown. Criteria: CRRSAA HEERF II and ARP HEERF II require that Institutional Aid Portions should be disbursed within 3 calendar days of the drawdown from G5. Cause: Personnel were not fully aware of the timeframe required for funds to be spend under the award agreement. Effect: The College was not in compliance with the Cash Management compliance requirement. Questioned costs: Not Applicable. Recommendation: The College should take action to ensure staff are trained to be knowledgeable of all requirements under federal awards it receives. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
Condition: It was noted during the audit that the amount of Pell awards granted to students was not accurately reported on the College’s annual Fiscal Operations Report and Application to Participate (FISAP). Criteria: Non-federal entities are required to submit the FISAP electronically, on an annual basis, for its campus-based programs to report expenditures in the previous award year. Cause: The Chief Financial Officer reported the incorrect amount of Pell awards disbursed to students. Effect: Inaccurate report was filed. Questioned costs: Not applicable. Views of Responsible Officials and Planned Corrective Actions: The College should establish a procedure that requires a separate review of the FISAP prior to submission. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.