Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-001: Failure to Maintain Proper Documentation of Time and Effort Reporting Condition Found: Carle did not have proper documentation of time and effort relating to personnel costs charged to the program. In testing of 40 selected payroll costs, Carle was unable to provide physical documentation of timesheets or other effort tracking for 16 samples to support the amounts allocated by percentage to the Illinois SOR2 award. Though Carle was able to provide rationale for the amounts allocated, including estimated time spent on the award, allocations do not meet standards for documentation of personnel expenses. Criteria or Requirement: 2 CFR 200.430(i) requires charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates alone do not qualify as support for charges to Federal awards. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure time charged to federal grants is appropriately tracked and certified. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. This was the first grant for the department and while internal controls were in place, it is clear they were not sufficient. Possible Asserted Effect: Failure to maintain appropriate documentation of personnel costs may lead to questioned costs or inaccurate reporting of federal expenditures. Repeat Finding:
A similar finding was reported in the prior year audit (2022-001). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its process for preparing and reviewing time tracking for federal awards and implement the procedures necessary to ensure documentation of personnel costs are complete and accurate. Views of Carle management: There is an understanding of this repeated finding, and a need for corrective action. Actions were taken in September 2023 when the finding was initially noted to improve internal controls and ensure compliance in maintaining proper documentation for time and effort reporting under federal awards.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards.
Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023-003: Over-awarding of subsidized Direct Loans Condition Found Methodist College (Carle) awarded and disbursed subsidized loans in excess of aggregate loan limits for the 2022 to 2023 aid year. In our testing of 40 samples, one student was awarded an aggregate of $24,500 for subsidized loans which exceeded the $23,000 limit for subsidized loans. Further, we noted that the review control over student aid packaging was not operating effectively in the period. The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which eligibility and disbursement requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528. Criteria Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and (for Direct Unsubsidized Loans) dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e) the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010) are $57,500 for independent undergraduate students (and for dependent students whose parents are unable to borrow Direct PLUS Loans, not more than $23,000 of which may be subsidized. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student aid awarded are within the limits set by USDE. Cause When reviewing files the FAFSA for this student showed a Sub award total of $19,000. Her original loan was disbursed for $2750. It seems likely that this students ISIR was looked at with the $19,000 SUB and awarded incorrectly based on the $19,000 figure. Possible Asserted Effect Inappropriate awarding of aid are considered questioned costs and may lead to penalties, repayments, and other corrective actions. Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure appropriate student aid packaging to ensure amounts do not exceed subsidized limitation guidelines. Views of Carle management: Methodist College agrees with the finding of an over award for the one student in question. Corrective Action Plan: In standing financial aid meetings, we will review Federal Loan limits and what our process/procedures are if a student is close to limits to insure, we don’t over award. Contact Person(s): Justina Kirchgessner Anticipated Completion Date:2024
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.
Finding 2023 004: Inaccurate and Untimely Enrollment Reporting Condition Found Methodist College did not accurately and/or timely report student address changes and student enrollment status changes at both the campus-level and program-level to the National Student Loan Data System (NSLDS). The U.S. Department of Education (USDE) uses enrollment data reported by the College to determine: (1) eligibility for interest subsidies, (2) loan repayment start dates, and (3) in-school loan deferments. The enrollment information is also used by USDE to measure program completion data to evaluate the effectiveness of financial aid programs. Additionally, changes in a student’s permanent address are used by USDE to service loans. During our testing of enrollment reporting at the College, we noted that no submissions were made to NSLDS for the period 4/1/2023 to 12/31/2023. Further, we noted review controls were not implemented in the period to ensure enrollment and student data submitted to NSLDS was accurate and sent in accordance with required timeframes.
The College disbursed FDL loans to 292 students and Pell grants to 193 students during the year ended December 31, 2023 for which enrollment reporting requirements applied. The number of undergraduate students enrolled in the College during fiscal year 2023 was 528.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half time basis or failed to enroll on at least a half time basis for the period for which the loan was intended. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student campus and program-level enrollment status changes and address changes are accurately and timely reported to the NSLDS. Cause In discussing these conditions with College officials, they stated that NSC was part of a security breach and when they were fixing their processes, Methodist College got incorrectly linked to Methodist University in Fayetteville, NC causing submissions to report incorrectly on our end. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status and student information affects the determinations that lenders and servicers of student loans make related to in school deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Repeat Finding A similar finding was not reported in the prior year audit. Statistical Sampling No sampling was performed. Recommendation We recommend the College review its procedures to ensure timely and accurate reporting of student information and enrollment status information to the NSLDS. Views of Carle management: Methodist College agrees with the finding of inaccurate and delayed submissions and have been working to get everything caught back up now that NSC has fixed their security breach and incorrectly linking us to the wrong college.