Audit 326482

FY End
2023-06-30
Total Expended
$1.93M
Findings
20
Programs
4
Organization: Cottey College (MO)
Year: 2023 Accepted: 2024-10-29
Auditor: Sikich CPA LLC

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
504081 2023-003 - - E
504082 2023-004 Significant Deficiency Yes E
504083 2023-005 - - N
504084 2023-005 - - N
504085 2023-006 - - E
504086 2023-007 Significant Deficiency - Cash Management
504087 2023-007 Significant Deficiency - Cash Management
504088 2023-007 Significant Deficiency - Cash Management
504089 2023-007 Significant Deficiency - Cash Management
504090 2023-008 - - E
1080523 2023-003 - - E
1080524 2023-004 Significant Deficiency Yes E
1080525 2023-005 - - N
1080526 2023-005 - - N
1080527 2023-006 - - E
1080528 2023-007 Significant Deficiency - Cash Management
1080529 2023-007 Significant Deficiency - Cash Management
1080530 2023-007 Significant Deficiency - Cash Management
1080531 2023-007 Significant Deficiency - Cash Management
1080532 2023-008 - - E

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $1.17M Yes 6
84.063 Federal Pell Grant Program $705,134 Yes 2
84.033 Federal Work-Study Program $29,746 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $25,644 Yes 1

Contacts

Name Title Type
J4C4KJBAAM33 Jerry White Auditee
4176678181 Ray Krouse Auditor
No contacts on file

Notes to SEFA

Title: FEDERAL LOAN PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards includes the federal grant activity of Cottey College and is presented on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: Y Rate Explanation: Cottey College does not have a negotiated indirect cost rate; therefore, it is limited to the 10% federal de minimis indirect cost rate until such time that it negotiates a different rate. For the year ended June 30, 2023, Cottey College acted as a pass-through agency for Direct Federal Stafford Loans (subsidized, unsubsidized and PLUS) to students and parents in the amount of $1,168,567.
Title: OTHER INFORMATION Accounting Policies: The accompanying schedule of expenditures of federal awards includes the federal grant activity of Cottey College and is presented on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: Y Rate Explanation: Cottey College does not have a negotiated indirect cost rate; therefore, it is limited to the 10% federal de minimis indirect cost rate until such time that it negotiates a different rate. Cottey College did not receive any federal insurance or federal noncash assistance and did not provide any amounts to sub-recipients.

Finding Details

2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student's estimated cost of attendance for the period of enrollment less the borrower's expected family contribution and estimated financial assistance for that period (34 CFR 685.203). Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,002 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend Cottey College reclassify $5,002 from subsidized to unsubsidized. 2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.164 (a)(1) states "Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student's ledger account or pays the student or parent directly with - (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: Cottey College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Questioned Costs: $16,444 Cause and Effect: Cottey College noted this was an error that occurred but did not occur with the entire batches. Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states "When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section." 34 CFR 668.22 (e)(2) states, "The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or..." 34 CFR 668.22(j) notes, "(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b)." An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student's account for outstanding charges (34 CFR 668.22). Condition: Cottey College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $32 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by Cottey College. Recommendation: We recommend Cottey College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states "When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section." 34 CFR 668.22 (e)(2) states, "The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or..." 34 CFR 668.22(j) notes, "(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b)." An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student's account for outstanding charges (34 CFR 668.22). Condition: Cottey College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $32 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by Cottey College. Recommendation: We recommend Cottey College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: In the case of an undergraduate student who has successfully completed the first and second years of a program of study of undergraduate education but has not successfully completed the remainder of the program, the total amount the student may borrow for any academic year of study under the Direct Subsidized Loan Program may not exceed the following: $5,500 for a program of study of at least an academic year in length (34 CFR 685.203). Condition: During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,436 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is students received unsubsidized loans prior to receiving full subsidized loans. Recommendation: We recommend Cottey College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: A student who has not successfully completed a program of study at the undergraduate level may not receive Federal Direct Subsidized Loans in excess of $23,000 (34 CFR 682.204). Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $1,969 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is a student received ineligible loan proceeds. Recommendation: We recommend Cottey College reclassify $1,969 from subsidized to unsubsidized. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student's estimated cost of attendance for the period of enrollment less the borrower's expected family contribution and estimated financial assistance for that period (34 CFR 685.203). Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,002 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend Cottey College reclassify $5,002 from subsidized to unsubsidized. 2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.164 (a)(1) states "Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student's ledger account or pays the student or parent directly with - (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: Cottey College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Questioned Costs: $16,444 Cause and Effect: Cottey College noted this was an error that occurred but did not occur with the entire batches. Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states "When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section." 34 CFR 668.22 (e)(2) states, "The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or..." 34 CFR 668.22(j) notes, "(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b)." An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student's account for outstanding charges (34 CFR 668.22). Condition: Cottey College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $32 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by Cottey College. Recommendation: We recommend Cottey College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states "When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section." 34 CFR 668.22 (e)(2) states, "The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or..." 34 CFR 668.22(j) notes, "(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b)." An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student's account for outstanding charges (34 CFR 668.22). Condition: Cottey College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $32 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by Cottey College. Recommendation: We recommend Cottey College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: In the case of an undergraduate student who has successfully completed the first and second years of a program of study of undergraduate education but has not successfully completed the remainder of the program, the total amount the student may borrow for any academic year of study under the Direct Subsidized Loan Program may not exceed the following: $5,500 for a program of study of at least an academic year in length (34 CFR 685.203). Condition: During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,436 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is students received unsubsidized loans prior to receiving full subsidized loans. Recommendation: We recommend Cottey College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: A student who has not successfully completed a program of study at the undergraduate level may not receive Federal Direct Subsidized Loans in excess of $23,000 (34 CFR 682.204). Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $1,969 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is a student received ineligible loan proceeds. Recommendation: We recommend Cottey College reclassify $1,969 from subsidized to unsubsidized. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.