FAC Explorer

Audit 308676

FY End
2023-06-30
Total Expended
$4.69M
Findings
22
Programs
4
Organization: Pillar College and Subsidiaries (NJ)
Year: 2023 Accepted: 2024-06-12
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
400618 2023-002 Material Weakness - N
400619 2023-002 Material Weakness - N
400620 2023-002 Material Weakness - N
400621 2023-002 Material Weakness - N
400622 2023-003 Material Weakness - EN
400623 2023-003 Material Weakness - EN
400624 2023-004 Significant Deficiency Yes N
400625 2023-004 Significant Deficiency Yes N
400626 2023-005 Significant Deficiency Yes E
400627 2023-006 - - C
400628 2023-006 - - C
977060 2023-002 Material Weakness - N
977061 2023-002 Material Weakness - N
977062 2023-002 Material Weakness - N
977063 2023-002 Material Weakness - N
977064 2023-003 Material Weakness - EN
977065 2023-003 Material Weakness - EN
977066 2023-004 Significant Deficiency Yes N
977067 2023-004 Significant Deficiency Yes N
977068 2023-005 Significant Deficiency Yes E
977069 2023-006 - - C
977070 2023-006 - - C

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $2.83M Yes 4
84.063 Federal Pell Grant Program $1.76M Yes 5
84.007 Federal Supplemental Educational Opportunity Grants $57,869 Yes 1
84.033 Federal Work-Study Program $41,879 Yes 1

Contacts

Name Title Type
NMWBFNX1UZQ3 Cindy Weaver Auditee
9738035000 Brent Smith, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO THE CONSOLIDATED FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards and state financial assistance (the schedule) includes the federal and state grant activity of Pillar College and Subsidiaries under programs of the federal and New Jersey state governments for the year ending June 30, 2023. 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) and New Jersey OMB Circular 15-08, Single Audit Policy for Recipients of Federal Grants, State Grants and State Aid (Circular 15-08). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. See the Notes to the SEFA for chart/table
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards and state financial assistance (the schedule) includes the federal and state grant activity of Pillar College and Subsidiaries under programs of the federal and New Jersey state governments for the year ending June 30, 2023. 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) and New Jersey OMB Circular 15-08, Single Audit Policy for Recipients of Federal Grants, State Grants and State Aid (Circular 15-08). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Pillar College and Subsidiaries did not provide any federal or state funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.

Finding Details

Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Disbursements to Ineligible Students Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, and 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College disbursed various federal financial assistance an ineligible student and to students who did not begin attendance in all the classes in the term for which the Title IV aid was disbursed. The College is to return Title IV aid within 30 days when the student fails to begin attendance. Criteria: 34 CFR 668.21 Questioned Costs: $9,276 Context: Out of 15 withdrawal students tested for proper aid disbursement, there were 9 for whom the College did not timely adjust the student’s aid based on their attendance records. This resulted in $12,661 of Pell and $13,857 of Federal Direct Loans (FDL) returned late to the Department of Education ranging from 54 to 264 days. As of the of the end of the audit, $9,571 of Pell and $7,671 FDL were returned to the Department of Education. Cause: There was a lack of communication between the Registrar and the Financial Aid Office when the students did not begin attendance. Professors did not provide confirmation of attendance timely to the Registrar. Effect: Students where disbursed aid for which they were ineligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College develop a process for communicating attendance changes in a timely manner between offices. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Disbursements to Ineligible Students Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, and 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College disbursed various federal financial assistance an ineligible student and to students who did not begin attendance in all the classes in the term for which the Title IV aid was disbursed. The College is to return Title IV aid within 30 days when the student fails to begin attendance. Criteria: 34 CFR 668.21 Questioned Costs: $9,276 Context: Out of 15 withdrawal students tested for proper aid disbursement, there were 9 for whom the College did not timely adjust the student’s aid based on their attendance records. This resulted in $12,661 of Pell and $13,857 of Federal Direct Loans (FDL) returned late to the Department of Education ranging from 54 to 264 days. As of the of the end of the audit, $9,571 of Pell and $7,671 FDL were returned to the Department of Education. Cause: There was a lack of communication between the Registrar and the Financial Aid Office when the students did not begin attendance. Professors did not provide confirmation of attendance timely to the Registrar. Effect: Students where disbursed aid for which they were ineligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College develop a process for communicating attendance changes in a timely manner between offices. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 14 modular students tested, the College returned Title IV funds for one student withdrawal that did not require funds to be returned based on the completion rate. Additionally, there was one student who had a return that was 262 days late. Cause: There was no timely review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 14 modular students tested, the College returned Title IV funds for one student withdrawal that did not require funds to be returned based on the completion rate. Additionally, there was one student who had a return that was 262 days late. Cause: There was no timely review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not properly awarded Pell. Criteria: 34 CFR 690.63(b) Questioned Costs: $13 Context: Out of 42 students tested, 2 student were not disbursed aid for all the classes they attended in a term resulting in $3,091 under award of Pell. 1 student was inadvertently over awarded Pell by $13. Cause: Changes in enrollment status were not caught. Effect: There was an incorrect amount of Pell paid to these two students. Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. We recommend that attendance in each module be confirmed by an academic related activity and financial aid office be notified so that appropriate changes to Pell awards can be made timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-006
Credit Balances Held Beyond Payment Period DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College is required to pay out credit balances created by federal aid within 14 days of the balance being created. Additionally, they are not allowed to hold credit balances beyond the end of the payment period. Criteria: 34 CFR 668.164(h) Questioned Costs: $0 Context: Out of 40 students tested for holding credit balances, there were 3 students who had a credit balance created by Federal Direct Loans and Federal Pell that were not paid out to the student before the end of the payment period. These were corrected during the course of the audit. Cause: There was not a process in place to identify credit balances created by federal aid within the 14 day time frame and again at the end of the payment period. Effect: Noncompliance with the Department of Education's cash management regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College design and implement a process to identify credit balances created by federal aid and disburse them to students within 14 days of the balance being created and to pay out all credit balances at the end of the payment period. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-006
Credit Balances Held Beyond Payment Period DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College is required to pay out credit balances created by federal aid within 14 days of the balance being created. Additionally, they are not allowed to hold credit balances beyond the end of the payment period. Criteria: 34 CFR 668.164(h) Questioned Costs: $0 Context: Out of 40 students tested for holding credit balances, there were 3 students who had a credit balance created by Federal Direct Loans and Federal Pell that were not paid out to the student before the end of the payment period. These were corrected during the course of the audit. Cause: There was not a process in place to identify credit balances created by federal aid within the 14 day time frame and again at the end of the payment period. Effect: Noncompliance with the Department of Education's cash management regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College design and implement a process to identify credit balances created by federal aid and disburse them to students within 14 days of the balance being created and to pay out all credit balances at the end of the payment period. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Disbursements to Ineligible Students Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, and 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College disbursed various federal financial assistance an ineligible student and to students who did not begin attendance in all the classes in the term for which the Title IV aid was disbursed. The College is to return Title IV aid within 30 days when the student fails to begin attendance. Criteria: 34 CFR 668.21 Questioned Costs: $9,276 Context: Out of 15 withdrawal students tested for proper aid disbursement, there were 9 for whom the College did not timely adjust the student’s aid based on their attendance records. This resulted in $12,661 of Pell and $13,857 of Federal Direct Loans (FDL) returned late to the Department of Education ranging from 54 to 264 days. As of the of the end of the audit, $9,571 of Pell and $7,671 FDL were returned to the Department of Education. Cause: There was a lack of communication between the Registrar and the Financial Aid Office when the students did not begin attendance. Professors did not provide confirmation of attendance timely to the Registrar. Effect: Students where disbursed aid for which they were ineligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College develop a process for communicating attendance changes in a timely manner between offices. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Disbursements to Ineligible Students Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, and 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College disbursed various federal financial assistance an ineligible student and to students who did not begin attendance in all the classes in the term for which the Title IV aid was disbursed. The College is to return Title IV aid within 30 days when the student fails to begin attendance. Criteria: 34 CFR 668.21 Questioned Costs: $9,276 Context: Out of 15 withdrawal students tested for proper aid disbursement, there were 9 for whom the College did not timely adjust the student’s aid based on their attendance records. This resulted in $12,661 of Pell and $13,857 of Federal Direct Loans (FDL) returned late to the Department of Education ranging from 54 to 264 days. As of the of the end of the audit, $9,571 of Pell and $7,671 FDL were returned to the Department of Education. Cause: There was a lack of communication between the Registrar and the Financial Aid Office when the students did not begin attendance. Professors did not provide confirmation of attendance timely to the Registrar. Effect: Students where disbursed aid for which they were ineligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College develop a process for communicating attendance changes in a timely manner between offices. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 14 modular students tested, the College returned Title IV funds for one student withdrawal that did not require funds to be returned based on the completion rate. Additionally, there was one student who had a return that was 262 days late. Cause: There was no timely review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 14 modular students tested, the College returned Title IV funds for one student withdrawal that did not require funds to be returned based on the completion rate. Additionally, there was one student who had a return that was 262 days late. Cause: There was no timely review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not properly awarded Pell. Criteria: 34 CFR 690.63(b) Questioned Costs: $13 Context: Out of 42 students tested, 2 student were not disbursed aid for all the classes they attended in a term resulting in $3,091 under award of Pell. 1 student was inadvertently over awarded Pell by $13. Cause: Changes in enrollment status were not caught. Effect: There was an incorrect amount of Pell paid to these two students. Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. We recommend that attendance in each module be confirmed by an academic related activity and financial aid office be notified so that appropriate changes to Pell awards can be made timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-006
Credit Balances Held Beyond Payment Period DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College is required to pay out credit balances created by federal aid within 14 days of the balance being created. Additionally, they are not allowed to hold credit balances beyond the end of the payment period. Criteria: 34 CFR 668.164(h) Questioned Costs: $0 Context: Out of 40 students tested for holding credit balances, there were 3 students who had a credit balance created by Federal Direct Loans and Federal Pell that were not paid out to the student before the end of the payment period. These were corrected during the course of the audit. Cause: There was not a process in place to identify credit balances created by federal aid within the 14 day time frame and again at the end of the payment period. Effect: Noncompliance with the Department of Education's cash management regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College design and implement a process to identify credit balances created by federal aid and disburse them to students within 14 days of the balance being created and to pay out all credit balances at the end of the payment period. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-006
Credit Balances Held Beyond Payment Period DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College is required to pay out credit balances created by federal aid within 14 days of the balance being created. Additionally, they are not allowed to hold credit balances beyond the end of the payment period. Criteria: 34 CFR 668.164(h) Questioned Costs: $0 Context: Out of 40 students tested for holding credit balances, there were 3 students who had a credit balance created by Federal Direct Loans and Federal Pell that were not paid out to the student before the end of the payment period. These were corrected during the course of the audit. Cause: There was not a process in place to identify credit balances created by federal aid within the 14 day time frame and again at the end of the payment period. Effect: Noncompliance with the Department of Education's cash management regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College design and implement a process to identify credit balances created by federal aid and disburse them to students within 14 days of the balance being created and to pay out all credit balances at the end of the payment period. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.