2023 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days or with the next roster file if such file is due within 60 days. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition:
Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs:
N/A
Context:
1.) During our testing of NSLDS Enrollment Reporting, we noted status change was received by NSLDS was outside of the 60 day timeframe for 20 of the 40 students sampled.
2.) During our testing of NSLDS Enrollment Reporting, we noted incorrect enrollment effective dates were reported to NSLDS for 4 of the 40 students tested and 2 of 40 students had the wrong enrollment status reported. During our testing of NSLDS Program Enrollment reporting, we noted incorrect program effective dates were reported to NSLDS for 1 of the 40 students tested and 1 of the 40 students tested had the incorrect status reported.
Cause:
The College policies and procedures did not ensure that student status changes were timely reported to NSLDS.
Effect:
The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.
Repeat Finding:
Yes - Finding 2022-004
Recommendation:
The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days or with the next roster file if such file is due within 60 days. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition:
Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs:
N/A
Context:
1.) During our testing of NSLDS Enrollment Reporting, we noted status change was received by NSLDS was outside of the 60 day timeframe for 20 of the 40 students sampled.
2.) During our testing of NSLDS Enrollment Reporting, we noted incorrect enrollment effective dates were reported to NSLDS for 4 of the 40 students tested and 2 of 40 students had the wrong enrollment status reported. During our testing of NSLDS Program Enrollment reporting, we noted incorrect program effective dates were reported to NSLDS for 1 of the 40 students tested and 1 of the 40 students tested had the incorrect status reported.
Cause:
The College policies and procedures did not ensure that student status changes were timely reported to NSLDS.
Effect:
The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.
Repeat Finding:
Yes - Finding 2022-004
Recommendation:
The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 004
Federal Agency: Department of Education
Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund
Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F201294; all grants were awarded within the 2019-20, 2020-21, 2021-22. 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement:
The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.
Condition:
During our testing of compliance, we noted that management had not provided proper documentation of review and had not maintained all reports on the College website.
Questioned Costs:
N/A
Context:
None of the reports tested had documented the review for the College’s reports. Additionally, one of the four quarterly reports was not displayed on the College’s website.
Effect:
The College is not complying with awarding requirements, which could affect the amount of Federal funding received.
Repeat Finding:
Yes – 2022-005
Recommendation:
The College should review their reporting internal controls and documentation of review around grant reporting to ensure all reporting requirements are being met and controls are documented.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 004
Federal Agency: Department of Education
Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund
Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F201294; all grants were awarded within the 2019-20, 2020-21, 2021-22. 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement:
The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.
Condition:
During our testing of compliance, we noted that management had not provided proper documentation of review and had not maintained all reports on the College website.
Questioned Costs:
N/A
Context:
None of the reports tested had documented the review for the College’s reports. Additionally, one of the four quarterly reports was not displayed on the College’s website.
Effect:
The College is not complying with awarding requirements, which could affect the amount of Federal funding received.
Repeat Finding:
Yes – 2022-005
Recommendation:
The College should review their reporting internal controls and documentation of review around grant reporting to ensure all reporting requirements are being met and controls are documented.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 005
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Under 34 DFR 668.164(1), an institution must have a process that ensures SFA funds never escheat to a State or revert to the institution or any other third party.
If disbursement of a student refund balance by check is not cashed, the school must return the funds no later than 240 days after the original issued check.
Condition:
The College did not void/return outstanding student refund balance checks within the 240-day time frame.
Questioned Costs:
$5,297 – outstanding checks untimely voided or not voided
Context:
During our testing of outstanding student refund checks we noted 6 of the 40 checks outstanding over 240 days were related to Title IV funding. Of these 6 checks, 5 were voided untimely and 1 was not voided as of August 31, 2023.
Effect:
As the result of not voiding issued student refund checks outstanding for over 240 days, the college is not in compliance with the corresponding requirement of the Department of Education.
Repeat Finding:
Not a repeat finding.
Recommendation:
The College should implement a control to establish an ongoing reconciliation of the outstanding refund check listing.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days or with the next roster file if such file is due within 60 days. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition:
Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs:
N/A
Context:
1.) During our testing of NSLDS Enrollment Reporting, we noted status change was received by NSLDS was outside of the 60 day timeframe for 20 of the 40 students sampled.
2.) During our testing of NSLDS Enrollment Reporting, we noted incorrect enrollment effective dates were reported to NSLDS for 4 of the 40 students tested and 2 of 40 students had the wrong enrollment status reported. During our testing of NSLDS Program Enrollment reporting, we noted incorrect program effective dates were reported to NSLDS for 1 of the 40 students tested and 1 of the 40 students tested had the incorrect status reported.
Cause:
The College policies and procedures did not ensure that student status changes were timely reported to NSLDS.
Effect:
The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.
Repeat Finding:
Yes - Finding 2022-004
Recommendation:
The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days or with the next roster file if such file is due within 60 days. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition:
Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs:
N/A
Context:
1.) During our testing of NSLDS Enrollment Reporting, we noted status change was received by NSLDS was outside of the 60 day timeframe for 20 of the 40 students sampled.
2.) During our testing of NSLDS Enrollment Reporting, we noted incorrect enrollment effective dates were reported to NSLDS for 4 of the 40 students tested and 2 of 40 students had the wrong enrollment status reported. During our testing of NSLDS Program Enrollment reporting, we noted incorrect program effective dates were reported to NSLDS for 1 of the 40 students tested and 1 of the 40 students tested had the incorrect status reported.
Cause:
The College policies and procedures did not ensure that student status changes were timely reported to NSLDS.
Effect:
The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.
Repeat Finding:
Yes - Finding 2022-004
Recommendation:
The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 004
Federal Agency: Department of Education
Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund
Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F201294; all grants were awarded within the 2019-20, 2020-21, 2021-22. 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement:
The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.
Condition:
During our testing of compliance, we noted that management had not provided proper documentation of review and had not maintained all reports on the College website.
Questioned Costs:
N/A
Context:
None of the reports tested had documented the review for the College’s reports. Additionally, one of the four quarterly reports was not displayed on the College’s website.
Effect:
The College is not complying with awarding requirements, which could affect the amount of Federal funding received.
Repeat Finding:
Yes – 2022-005
Recommendation:
The College should review their reporting internal controls and documentation of review around grant reporting to ensure all reporting requirements are being met and controls are documented.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 004
Federal Agency: Department of Education
Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund
Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F201294; all grants were awarded within the 2019-20, 2020-21, 2021-22. 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement:
The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.
Condition:
During our testing of compliance, we noted that management had not provided proper documentation of review and had not maintained all reports on the College website.
Questioned Costs:
N/A
Context:
None of the reports tested had documented the review for the College’s reports. Additionally, one of the four quarterly reports was not displayed on the College’s website.
Effect:
The College is not complying with awarding requirements, which could affect the amount of Federal funding received.
Repeat Finding:
Yes – 2022-005
Recommendation:
The College should review their reporting internal controls and documentation of review around grant reporting to ensure all reporting requirements are being met and controls are documented.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.
2023 – 005
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Under 34 DFR 668.164(1), an institution must have a process that ensures SFA funds never escheat to a State or revert to the institution or any other third party.
If disbursement of a student refund balance by check is not cashed, the school must return the funds no later than 240 days after the original issued check.
Condition:
The College did not void/return outstanding student refund balance checks within the 240-day time frame.
Questioned Costs:
$5,297 – outstanding checks untimely voided or not voided
Context:
During our testing of outstanding student refund checks we noted 6 of the 40 checks outstanding over 240 days were related to Title IV funding. Of these 6 checks, 5 were voided untimely and 1 was not voided as of August 31, 2023.
Effect:
As the result of not voiding issued student refund checks outstanding for over 240 days, the college is not in compliance with the corresponding requirement of the Department of Education.
Repeat Finding:
Not a repeat finding.
Recommendation:
The College should implement a control to establish an ongoing reconciliation of the outstanding refund check listing.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.